Privacy Notice

Introduction

This Privacy Notice gives you information about how Think Divergent Ltd (hereafter “ThinkDivergent”) collects and uses your personal data through your use of our app and when you communicate with us in any way, including any data you may provide when you sign up and use our services. This notice applies to all users who interact with ThinkDivergent, whether through our platform, our website, or any other means. You may be using our platform in a professional capacity, as someone receiving care or assessment, or as someone supporting that process. Where a section applies only to a specific group of users, this is clearly indicated within that section.

Who we are and how to contact us

ThinkDivergent (collectively referred to as, "we", "us" or "our" in this Privacy Notice)  is a company registered in England and Wales with company number 15477852 with its registered office at 37 Warren St, London W1T 6AD.

Our company details and our registration with the UK’s Data Protection Regulator (the ICO) can be found here: https://ico.org.uk/ESDWebPages/Entry/ZB730364

If you would like to contact us about anything in this Privacy Notice, or if you have any questions about how we use your information or if you would like to exercise any of your data subject rights, please contact us here: tom@thinkdivergent.co.uk

ThinkDivergent as a Data Processor

ThinkDivergent acts as a data processor when processing patient data. This means we only process personal data in accordance with the instructions of the data controller, which is the organisation providing care (such as a GP practice, hospital, hospice, pharmacy, or care home). These organisations retain overall responsibility for patient data and determine the purposes and lawful basis for processing.

In this context, ThinkDivergent processes data on behalf of the user’s organisation (the data controller), which determines the lawful basis for processing. In most cases, the data controller relies on:

• Article 6(1)(e) UK GDPR – processing necessary for the performance of a task carried out in the public interest

• Article 9(2)(h) UK GDPR – processing necessary for the provision of health or social care

The National Data Opt-Out is a service that allows patients to opt out of their confidential patient information being used for research and planning. As a data processor, ThinkDivergent does not apply or manage these preferences; this is the responsibility of the data controller. You can find out more about opting out here.

The types of personal data we collect about all the users of our app

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes email address, first name, last name for all users. Depending on how you use the platform, this may also include title, date of birth, and gender. Where you are a Healthcare Provider, we may also collect information relating to your professional qualifications.

• Contact Data includes billing address, delivery address, and telephone numbers for Healthcare Providers.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you interact with and use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Health Data (Special Category Data) includes information relating to your physical or mental health, including questionnaire responses, screening data, and clinical assessment information. This data is classified as special category personal data under UK GDPR and is subject to additional protections.

We also collect, use and share anonymised aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may use this anonymised data for the purposes of helping us build evidence to justify formal clinical trials and feasibility studies in a clinical setting, or for internal research and product development, including product development involving machine learning and big data analysis, or for future publications.

1. How is your personal data collected?

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

Your interactions with us. You may give us your personal data by signing up to use the web app, filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data, you provide when you:

• create an account to use the ThinkDivergent web app; either by registering directly or via an invitation from an authorised organisation or individual

• sign in to use the ThinkDivergent web app

• subscribe to our newsletters or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

Automated technologies or interactions. As you interact with our app, we will automatically collect Technical Data about your equipment, browsing actions and patterns.

2. How we use your personal data

2.1 Legal basis

The law requires us to have a valid legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform a contract we are about to enter into, or have entered into, with you. This may also apply where we process your data in connection with a contract between you and an organisation that has invited you to use the platform, such as your healthcare provider, employer, or educational institution.

• Legitimate interests: We may use your personal data where it is necessary for the purposes of our legitimate interests, such as operating and improving our services, preventing fraud, and ensuring a secure user experience. We carefully consider and balance any potential impact on your rights and freedoms before processing your personal data on this basis. We do not rely on legitimate interests where such interests are overridden by your rights, unless we have your consent or are otherwise permitted or required to do so by law. When relying on this basis, we assess:
• Purpose - whether the processing has a legitimate aim
• Necessity - whether the processing is necessary to achieve that aim
• Balance - whether your interests, rights, or freedoms outweigh our legitimate interests

• Legal obligation: We may process your personal data where it is necessary to comply with a legal obligation to which we are subject. Where we rely on this basis, we will identify the relevant legal obligation.

• Consent: We rely on consent only where we have obtained your clear and explicit agreement to process your personal data for a specific purpose. You have the right to withdraw your consent at any time.

2.2 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

2.3 Direct marketing

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to You.

You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at  tom@thinkdivergent.co.uk.

2.4 Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

2.5 Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at  tom@thinkdivergent.co.uk.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

2.6 Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

• Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking and Performance Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

2.7 Use of automated technologies

We may use automated technologies, including large language models (LLMs), to support administrative functions such as structuring or summarising information for draft clinical documentation.

Where such technologies are used:

• No directly identifiable personal data (e.g. names, contact details) is transmitted

• Data is anonymised or masked prior to processing

• Outputs are reviewed and validated by a qualified clinician

• No automated decisions are made about your care

These tools are used solely to support clinicians and do not replace professional judgement.

3. Disclosures of your personal data

ThinkDivergent primarily acts as a data processor when providing its platform to healthcare organisations (e.g. NHS Trusts, clinics, or other care providers). In this context, we process personal data strictly on the documented instructions of the relevant healthcare organisation, which acts as the data controller and is responsible for determining the lawful basis for processing.

In limited circumstances, ThinkDivergent may act as a data controller, for example when processing personal data for account management, service improvement, analytics, or direct communications with users.

Where we act as a processor, the data controller is responsible for informing you how your data is used and for responding to your data protection rights.

We may share your personal data where necessary with external third parties who provide services to us, e.g: cloud service providers and technology services, or clinical research organisations. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We have Data Processing Agreements in place with these third party providers and we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not sell your data to anyone and only share it with our contracted processors.

Key categories of processors include:

• Cloud infrastructure providers (e.g. hosting, databases)

• Email delivery services

• Analytics and monitoring tools

A list of current subprocessors is available upon request.

3.1 Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. Alternatively, we may seek to acquire other businesses or merge with them. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.  

3.2 Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

3.3 Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

4. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK or EEA to countries which have laws that do not provide the same level of data protection as the UK or EU law.

Whenever we transfer your personal data out of the UK or EEA to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK or the EU to provide an adequate level of protection for personal data; or

• We may use specific standard contractual terms approved for use in the UK and/or EEA which give the transferred personal data the same protection as it has in the UK or EEA, or another transfer mechanism which has been approved by the relevant regulator in the UK and/or the EEA.

Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, including the use of International Data Transfer Agreements (IDTAs).

5. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we 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.

6. Data retention

6.1 How long will you use my personal data for?

Your information is securely stored. ThinkDivergent will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice.

Where ThinkDivergent acts as a data processor, Personal Data is retained in accordance with the instructions of the relevant data controller (e.g. NHS organisation), including applicable NHS records management policies.

Where we act as a data controller, we retain Personal Data only for as long as necessary for the purposes set out in this Privacy Notice.

We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

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.

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.

7. Protecting your sensitive data

ThinkDivergent follows the information security values of

• confidentiality - making sure your information is always kept secret and private;

• integrity - we ensure the completeness, consistency, and accuracy of the data over its lifecycle; and

• availability - we ensure the right information is available to the right person at the right time.

We use the following techniques and best practices to protect your sensitive data:

7.1 People

• Training - All staff receive regular appropriate training on data protection and security and their related duties to ensuring your personal data is secure;

• Minimised access: your personal data, including Health Data, can only be accessed on a strictly needs to know basis by our admin staff, or customer support as and when necessary, specifically as relates to your particular request for support;

• Security expertise: To design and operate our platform, we utilise qualified security professionals with recognised experience and certifications in technical security architecture as well as governance, risk, and compliance.

7.2  Cyber resiliency, business continuity, and disaster recovery

• We utilise the most secure and resilient infrastructure from Google Cloud Platform (GCP) which ensures servers are always patched and up to date.

• Web servers store no sensitive information - this is retrieved from an encrypted database accessible only via secure protocols (HTTPS). Automated tests are performed internally across the codebase on every commit.

• In addition, we commit to undertaking annual third-party security audits with certified security auditors including web application penetration tests to ensure comprehensive coverage.

7.3 Technology

We adopt principles of Secure by Design, including:

• Architecture in line with industry standards.

• This includes role based access controls.

• Our REST APIs utilise authentication and authorization to ensure data minimization and prevent unauthorised access to data.

• Our password quality validation for users ensures only strong passwords are allowed and are securely hashed using industry-standard cryptographic hashing algorithms with appropriate salting and strengthening techniques.

We use encryption in all of the following scenarios:

• In transit using modern protocols (TLS only) and secure ciphers

• At rest using AES-256 encryption

Data centres:

• We host data in multiple availability zones/regions in order to maximise availability. All production environments are located within the UK and EEA.

• Where possible, deploy a High Availability (HA) architecture to ensure resilience with automated failover to provide uninterrupted service.

Development, security & operations:

• We operate a mature secure software development life cycle (SDLC), which includes but is not limited to:

• Separation of keys for each environment and robust key management processes

• Regular dependency and package management audits and remediation

• Logical separation of production and development environments including isolated databases

• Static code testing to ensure code is free from known vulnerabilities

• Dynamic code testing to ensure applications do not expose vulnerabilities

• Manual security testing (annual penetration test)

8. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.

• 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.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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.

• If you wish to exercise any of the rights set out above, please contact us tom@thinkdivergent.co.uk

Where ThinkDivergent is the data processor (for example, if a Trust or GP is the controller), to find out more about how your data is protected by them, or to exercise your rights under data protection law, you should contact them directly.

8.1 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.

8.2 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8.3 Time limit to respond

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.

9. Contact details

If you have any questions about this Privacy Notice or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: tom@thinkdivergent.co.uk

10. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

11. Changes to the Privacy Notice and your duty to inform us of changes

We keep our Privacy Notice under regular review. This version was last updated in May 2026.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

12. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

13. Payments

This section only applies to those directly billed by ThinkDivergent.

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Notice.

14. National Data Opt-Out (UK)

At this time, we do not share any personal data for planning or research purposes for which the national data opt-out would apply. We review all of the confidential patient information we process on an annual basis to see if this is used for research and planning purposes. If it is, then individuals can decide to stop their information being shared for this purpose. You can find out more information at  https://www.nhs.uk/your-nhs-data-matters/