If you or your practice are based in the United States, then the US version of our Terms of Service and the US version of our End User Terms apply to you.
If you or your practice are not in the United States, then the outside USA version of our Terms of Service and outside USA version of our End User Terms apply to you.
1. Important Information and Who We Are
This Privacy Policy aims to give you information on how Physitrack and our group companies collect, process, and secure your personal data.
Physitrack PLC and/or our group companies are the controller and responsible for your personal data (collectively referred to as "Physitrack", "we", "us" or "our" in this Privacy Policy).
Data Protection Officer: dpo@physitrack.com. Address: 4th Floor, 140 Aldersgate Street, London, EC1A 4HY.
This version was last updated on July 2026.
2. The Data We Collect About You as Controller
We collect, use, store and transfer different kinds of personal data about Health Practitioners, corporate representatives, patients, students and companies using the Services, including: Identity Data (e.g. name, NHS ID); Contact Data (address, email, telephone); Customer Relationship Data (business name, job title, communications records); Transaction Data (payment details and purchases); Technical Data (IP address, login data, browser information); Profile Data (API token, password, preferences); Usage Data (service usage information); Marketing and Communications Data (newsletter preferences); Financial Data (bank/credit card details); and Service Data (analytics and performance data).
For patients and students, we collect Usage Data, Contact Data, Identity Data, Health Data and Technical Data.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose, as this does not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you as controller (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
3. The Data We Collect About You as Processor
We act as a processor to Health Practitioners, and we collect data on their behalf, including Special Category data such as your NHS ID, which exercises have been assigned to you, and your adherence to them. Data retention for this processed data follows the Physitrack Data Retention Policy.
4. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through: direct interactions, where you may give us your Identity, Contact and Financial Data by filling in forms, by corresponding with us by post, phone, email, chatbot or otherwise; automated technologies, where we (and our third-party partners) automatically collect Technical Data as you interact with our website, using cookies and similar technologies; and third parties, from whom we may receive data such as payment providers, LinkedIn, and Health Practitioners.
5. How We Use Your Personal Data
We have set out below, in a table format, a description of the ways we plan to use your personal data as the controller, and which of the legal bases we rely on to do so.
6. Disclosures of Your Personal Data
We may share your personal data for business and commercial purposes, such as operating the Services, with the parties set out below for the purposes set out in the table above:
- Health Practitioners who use the Services to collect and process your personal data.
- Service providers acting as processors who provide IT, hosting and system administration services identified at support.physitrack.com/subprocessors.
- Affiliates as a controller and/or processor for business and commercial purposes (meaning Physitrack's own corporate group of companies — see "Affiliates" in the Glossary. This is distinct from Affiliate Partners, described below, who are external to the Physitrack group).
- Affiliate Partners — external commercial, referral, reseller or commission-based partners with whom we operate a discount code, referral or affiliate programme (see "Affiliate Partners" in the Glossary), for the purpose of administering that arrangement and calculating and paying commission owed to them. We only share the minimum data necessary for this purpose — typically your name, email address, and the status of your trial or subscription — and, where reasonably practicable, we will notify you at the point you use a discount or referral code that this sharing may occur.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other governmental authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
7. International Transfers
Where necessary, we may need to transfer your personal data to another country to enable us to provide you with our Services, for marketing purposes and for customer relationship management purposes. Many of our external third parties are based outside the country in which you reside so their processing of your personal data may involve a transfer of data outside of the country in which you reside.
How we safeguard personal data when we transfer it internationally
Whenever we transfer your personal data out of your country, we take reasonable steps to ensure a similar degree of protection is afforded to it by using at least one of the following safeguards:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data under applicable law; or
- Where we use certain service providers, we may use specific contracts approved for use in your country which give personal data the same protection it has in your country.
For further details of the specific mechanisms we rely on where we transfer your data internationally, please see support.physitrack.com/article/721-what-types-of-data-are-stored-by-physitrack.
8. Data Security
We have put in place reasonable security measures designed to meet the requirements of applicable law and to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Although we make efforts to secure your personal data, we cannot guarantee the safety of any personal data you transmit to us online. In addition, we strive to 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any contractual, legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our Data Retention Policy (physitrack.com/data-retention-policy). Once the appropriate retention period has expired we will erase your data securely.
In some circumstances you can ask us to delete your data: see the "Your Legal Rights" section of this Policy for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. EU Representative
Our representative within the EU with respect to our obligations under European data protection law is Physiotools Oy, incorporated and registered in Finland with company number 0491074-9, whose address is Kehräsaari B, 5th Floor, 33200 Tampere, Finland. Email: data.protection@physiotools.com.
11. Your Legal Rights
Depending on where you live, you may have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data's accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at dpo@physitrack.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you and to follow certain procedures to help us verify the request, confirm your identity, and ensure your right to access your personal data (or to exercise any of your other rights). The verification steps we take may differ depending on your country of residence and the request. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it in accordance with applicable law. If we cannot verify your request, we may ask you for additional information to help us verify your request. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We will respond to your request within the time period required by applicable law. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. Considerations in the United States
Identifiable Patient information in the United States is treated as Protected Health Information (as defined at 45 C.F.R. § 160.103) ("PHI") regulated by the U.S. Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations ("HIPAA"). PHI is handled by us in accordance with our HIPAA business associate agreements ("BAAs") with the relevant Health Practitioners.
In the United States, we use and retain any PHI that we receive as a processor to provide and improve the Services and our products and services to the extent permitted by HIPAA and applicable agreements with our customers. We use and disclose PHI in accordance with HIPAA and applicable BAAs.
In the United States, we also may disclose PHI in accordance with HIPAA and the applicable BAAs or as directed by you. You are solely responsible for any disclosure of your personal data that you initiate using the Services.
NEW: In addition to our position on HIPAA and Protected Health Information set out above, this section also explains our position under United States state laws that regulate personal data more broadly, which may apply to you even where HIPAA does not.
US state privacy law disclosures
If you are a resident of a US state that has its own comprehensive consumer privacy law (currently including, among others, California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, Iowa, Indiana, Kentucky, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee and Minnesota), you may have some or all of the following rights, in addition to those set out in the "Your Legal Rights" section above, to the extent given by the law of your state: the right to know and access the categories and specific pieces of personal data we have collected about you; the right to correct inaccurate personal data; the right to delete personal data we hold about you; the right to opt out of the sale of personal data, the "sharing" of personal data for cross-context behavioural advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; the right to data portability; and the right to appeal our refusal to act on a request.
We do not discriminate against you for exercising any of these rights. To exercise a right described in this section, please contact us at dpo@physitrack.com. We may need to verify your identity before responding, as described in the "Your Legal Rights" section above. You may also designate an authorised agent to make a request on your behalf, subject to our ability to verify the agent's authority to act on your behalf.
Washington "My Health My Data Act" notice
Washington State's My Health My Data Act ("MHMD") requires businesses that collect "consumer health data" relating to Washington consumers to provide certain disclosures. "Consumer health data" is data that identifies a consumer's past, present or future physical or mental health status, and can include information such as health conditions or diagnoses, or the fact that an individual has sought health services — which may be relevant to some of the Health Data we process, as a processor, on behalf of Health Practitioners for their patients and other end users based in Washington.
Where MHMD applies to our processing of consumer health data, we collect this data for the purposes described in the "How We Use Your Personal Data" table above (in particular, to provide the Services on behalf of the relevant Health Practitioner). We do not sell consumer health data, and we do not use geofencing around healthcare facilities, as those terms are defined under MHMD.
Washington consumers may have the right to confirm whether we are collecting, sharing or selling their consumer health data, to withdraw consent for such collection or sharing, and to have such data deleted, subject to the exceptions set out in MHMD. To exercise these rights, please contact us at dpo@physitrack.com.
13. Considerations in Australia
If the Australian Privacy Act 1988 (Cth) ("Privacy Act") applies to the handling of your personal data, this clause will apply.
In this Privacy Policy, any references to "Special Categories of Personal Data" are taken to be references to "sensitive information" as set out in the Privacy Act. We will collect, use or disclose sensitive information about you only as permitted by law, for example where we have received your consent to do so or the collection is required or authorised by law.
For the purposes of clause 7 (International Transfers) of this Privacy Policy, we may transfer your personal data to overseas recipients (i.e. outside Australia) as set out under the list of Physitrack's Third Party Vendors (sub-processors) which can be found at support.physitrack.com/article/721-what-types-of-data-are-stored-by-physitrack.
14. Considerations in New Zealand
If the New Zealand Privacy Act 2020 ("NZ Privacy Act") applies to the handling of your personal data, this section will apply.
We will also comply with the New Zealand Health Information Privacy Code 2020 ("HIP Code") when collecting your health information.
We will collect personal data directly from you unless (i) you have authorised the collection of personal data from a third party, (ii) it would not prejudice you for collection to occur through a third party, (iii) collection from you would prejudice the purpose of collection, or (iv) it is not reasonably practicable to collect from you and the information will not be used in a form whereby you are identifiable.
For the purposes of section 7 (International Transfers) of this Privacy Policy, we may transfer your personal data to overseas recipients (i.e. outside New Zealand) located in the countries as set out under the list of Physitrack's Third Party Vendors (sub-processors) which can be found at support.physitrack.com/article/721-what-types-of-data-are-stored-by-physitrack.
15. Glossary
Affiliates — means Physitrack PLC together with its direct and indirect subsidiary and parent companies from time to time (i.e. Physitrack's own corporate group). This is distinct from "Affiliate Partners", defined below.
Affiliate Partners — means external, third-party individuals or businesses with whom we have a commercial, referral, reseller or commission-based arrangement — for example, an individual or company who refers customers to us using a discount or referral code in exchange for commission. Affiliate Partners are not part of the Physitrack group and act as an independent controller of any personal data we share with them for the purposes of that arrangement.
Legitimate Interest — means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract — means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation — means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third Party — means any natural person or legal entity which is not part of the Physitrack group, but which Physitrack has a contractual engagement with for the purposes of receiving services.
(Identity Data, Contact Data, Customer Relationship Data, Transaction Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data, Financial Data and Service Data are each described in Section 2 above.)
