Privacy Policy

About Our Engagement:

Randox Health London Ltd (“Randox”) has been subcontracted by Spectrum Wellness UK Limited (Spectrum.Life) working with AXA, to provide clinical services.

In the context of the services described in this policy, Randox acts as a data controller only in relation to the clinical laboratory services it provides—specifically, the testing and analysis of blood samples, and any associated obligations under applicable healthcare and laboratory regulations. For other aspects of the service, such as the receipt of registration information and logistical support, Randox acts as a data processor on behalf of Spectrum.Life and AXA. Randox will only process personal data in these cases based on documented instructions from Spectrum.Life or AXA, and not for its own purposes. This distinction ensures that data protection responsibilities are clearly defined and aligned with applicable UK GDPR and Data Protection Act 2018 requirements. In the provision of these services, Randox will use affiliated company, Randox Laboratories Limited, to perform practical and logistical support with regard to shipping sample collection kits, and Clinical Laboratory Services associated with testing. Randox shall ensure that any third parties involved in the performance of our obligations shall be subject to the same standards of Privacy as detailed in this policy.

The terms of your interactions with us these will be governed by your employer’s contractual relationship with AXA under which AXA provides it with health and wellbeing services. This policy details how Randox will process the data that we have either been provided by Spectrum.Life, or that we collect about you, to fulfill our contract obligations in compliance with all applicable Data Protection legislation associated with the service, as detailed in this policy.

We are fully committed to protecting your privacy in compliance with the UK GDPR and the UK Data Protection Act 2018

Principles of Data Processing

We adhere to the following principles to ensure your data is handled responsibly:

1. Lawfulness, Fairness, and Transparency: All processing activities comply with legal obligations and are conducted fairly and transparently.
2. Purpose Limitation: Personal data is processed only for specified, legitimate purposes.
3. Data Minimisation: We collect only the minimum data necessary for the intended purposes.
4. Accuracy: We strive to keep personal data accurate and up-to-date.
5. Storage Limitation: Data is retained only as long as necessary for its intended purpose.
6. Integrity and Confidentiality: Appropriate technical and organisational measures protect data against unauthorised access, loss, or misuse.

How will we use your User Data?

Spectrum.Life will provide Randox with some personal data that you complete in the Remote Health Assessment form, including your name and contact information, DOB, biological sex (M or F), and some identification references used to process your order.

Randox shall communicate the necessary details to our logistical partner to enable the shipping of a “Test Your Health” home sample collection kit to you. Once you have used the sample collection kit, you will need to register the kit on our Randox platform. This will require you to provide us with the following:

Your sample will be tested and results will be published on a private portal and accessed by Spectrum.Life. Spectrum.Life will be in touch with you directly thereafter.

Due to the scientific process associated with our services, on rare occasions, testing cannot be completed, or results may be inconclusive. In such circumstances, we may contact you via email or telephone to arrange for further sample collection. This may be via a re-issue of a “Test Your Health” home sample collection kit.

What is “User Data” as used in this privacy policy?

“User Data” means information that you upload, insert or provide to Randox. Some User Data may identify an individual or could be used to identify an individual and which is submitted to and/or collected, in this instance, by Randox Web Sites or Software.

Examples of User Data:

User Data may include, but is not limited to, names, postal address, e-mail address, and telephone number, which is known as Personally Identifiable Information or “PII.” PII is subject to strict privacy laws.

If we collect, use, and are responsible for certain PII about you in the provision of our services, then we do so at all times in compliance with Data Protection Legislation.

User Data that is processed by Randox in order to deliver the AXA services is logically/technically ring-fenced from data processed by Randox for other services that it provides. It is also processed on the basis of fewer categories and purposes than those described in Randox’s full privacy notice, which is why this bespoke privacy notice applies.

User Data: User Data-Marketing

Randox will not use any of your User Data that it acquires as a result of its relationship with Spectrum.life working with AXA for any marketing purposes.

How long will Randox store User Data?

In general, Randox will only store your User Data for as long as it is needed to fulfill the purposes for which it was collected, subject to applicable data retention periods imposed upon Randox or Spectrum.Life by applicable law.

Cookie Policy

The health and wellbeing services available to you from within the AXA Health App are provided by Spectrum Wellness UK Ltd (‘Spectrum.Life’).

1. Introduction

Spectrum.Life uses cookies and similar tracking technologies via the App to enhance user experience, personalise content, and analyse site traffic. This Cookie Policy explains what cookies are, how we use them, and how you can manage your preferences.

2. What Are Cookies?

Cookies are small text files stored on your device when you visit a website or use an App. They help websites and Apps remember user preferences and interactions to improve functionality and performance.

3. Types of Cookies We Use

We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the operation of our website and services. Without these, core functionalities such as login authentication cannot be provided.
• Performance Cookies: Collect anonymous data on how users interact with our website to help us improve functionality.
• Functional Cookies: Allow us to remember your preferences and personalise your experience.

4. How We Use Cookies

Cookies are used to:

• Provide secure access to our services and maintain session security.
• Improve user experience by remembering preferences and login details.
• Monitor website performance and optimise content.
• Support analytics and statistical analysis to improve our digital platforms.

5. Managing Cookies

You can control or disable cookies through your device settings or the cookie preference tool available within the App. Note that restricting certain cookies may impact service functionality.

For more details on how Google Analytics collects and processes data, visit Google’s Privacy Policy: https://policies.google.com/technologies/cookies

Information on OneTrust’s cookie management can be found here: https://www.onetrust.com/cookie-policy/

6. Third-Party Cookies

Some cookies are placed by third-party services that appear in the App, such as analytics providers and advertising networks. We recommend reviewing their privacy and cookie policies for further information.

7. Updates to This Cookie Policy

We may update this Cookie Policy periodically to reflect changes in legal requirements or how we use cookies. Please review this page regularly for the latest information.

Your Rights Under GDPR

You have the following rights regarding your personal data:

• Access: Request a copy of your personal data.
• Correction: Rectify inaccurate data.
• Erasure: Request deletion of your data in specific circumstances.
• Restriction: Request limited processing.
• Portability: Receive your data in a structured, commonly used format.
• Objection: Object to processing based on legitimate interests.
• Withdraw Consent: Withdraw your consent at any time where applicable.

Within the AXA Health App, AXA Health, Spectrum.Life and Randox each separately and independently process your data, so there are different contacts for exercising your rights, depending on what personal data processing you are interested in.

Spectrum.Life

For rights requests relating to the use of EAP, Events, Learn, Health coaching, Mental Wellbeing coaching, Cancer coaching, Health assessments (Know your numbers, glucose and cholesterol, wellbeing consultation, DIY checkpoint) and Health score within the App, please contact gdprspectrumlife@spectrum.life

Contact and Complaints

For concerns about your data, please contact our Data Protection Officer:

Data Protection Officer

Spectrum Wellness UK Limited
Habib House, 9 Stevenson Square, Manchester, M1 1DB, UK
Email: gdprspectrumlife@spectrum.life