Privacy Notice

PrivaPay Ltd · Version 1.0 · Effective 14 September 2026

This notice explains how PrivaPay Ltd ("PrivaPay", "we", "us") handles personal information. It covers patients who are billed through our platform, and the staff of the providers, insurers and partners we work with.

1. Who we are

PrivaPay Ltd is a company registered in England and Wales, company number 16804815.

We operate a payments platform for UK and Irish private healthcare. We take out-of-pocket patient payments for providers, and we settle approved insurer claims.

Contact for any privacy question, including to exercise your rights: privacy@privapay.health, or write to us at our registered office.

2. Our role — this matters for what you can ask us

We act in two different capacities, and which one applies determines who you should approach.

As a processor. When a hospital, clinic, consultant or billing bureau uses our platform to invoice you, they decide what to bill and why. We act on their instructions.

As a controller. We decide how we use information in our own right for: our website and cookies; our own business records; fraud prevention and platform security; and the identity checks we are required to carry out on business customers.

If you are a patient asking to see, correct or erase your billing record, contact the provider who treated you. We will help them respond, and we will tell you who to approach if you come to us first.

3. Information we handle

Patients

We do not receive or store your full card number or CVV. Card details are captured directly by our payment provider.

Providers, insurers, partners and their staff

Website visitors

The marketing site does not record pages viewed, referrer, approximate location, or cookie identifiers. See section 12.

4. Why we use it, and our lawful basis

Where we rely on legitimate interests we have assessed that our interest does not override your rights.

What we doLawful basis (UK GDPR Article 6; EU GDPR Article 6 for individuals in the EEA)
Issue invoices, take payments, operate payment plans, process refundsContract, or legitimate interests where the contract is between you and your provider
Settle approved insurer claims and produce remittance and reconciliation files for providersLegitimate interests, accurate settlement between provider and insurer
Send you transactional messages about your bill or payment (section 7)Contract and legitimate interests
Prevent and investigate fraud, secure our systems, meet PCI DSS obligationsLegitimate interests; legal obligation
Identity verification, sanctions screening and anti-money-laundering checks on business customersLegal obligation
Keep accounting, tax and audit recordsLegal obligation
Handle complaints, disputes, chargebacks and legal claimsLegitimate interests; legal claims
Manage our relationships with providers, insurers and partners, and market our services to businessesLegitimate interests
Improve the platform, monitor service quality and produce aggregated statisticsLegitimate interests
Marketing messages that need your permissionConsent

Health information. Invoice and claim data reveals that you received healthcare and often what kind.

We do not use your health information for marketing, profiling or automated decision-making.

5. Automated decision-making

We do not make decisions about you that produce legal or similarly significant effects using automated processing alone.

6. Who we share information with

Every supplier that processes personal information on our behalf acts under a written contract that restricts them to our instructions. Some recipients — such as card schemes, banks, regulators and professional advisers — receive information as independent controllers and are bound by their own legal and regulatory obligations.

We do not sell personal information to anyone, and we do not share it with third parties for their own marketing.

7. Text messages and emails

We send messages about your bill, for example that an invoice is ready, a payment link, a receipt, a payment plan reminder, a failed payment, or a refund confirmation. We send them because you are being billed for treatment, not to sell you anything.

How you come to receive them

Your mobile number reaches us in one of three ways: your provider gave it to us as part of instructing us to bill you; you gave it to us directly on a payment page or form; or you sent us a message first. Where we ask for your number on our own forms, we tell you at that point what we will send and how often.

Frequency

Message volume varies with your account. Typically this is fewer than six messages per bill. We do not send recurring campaign messages.

Opting out

Contact us at privacy@privapay.health. Opting out of texts does not stop us contacting you by other means about money you owe, and does not cancel a payment plan or a debt — we will write to you by email or post instead.

Costs

Message and data rates may apply, depending on your mobile plan and where you are.

What we do with messaging data

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text-message opt-in data and consent will not be shared with, sold, rented, or transferred to any third parties, affiliates or lead generators for marketing, promotional or lead-generation purposes.

We share your mobile number only with the communications providers and mobile networks that are needed to deliver the message to your handset — Twilio and the carriers — and with your treating provider, whose record it is. Twilio acts under our data processing agreement and may use your number only to deliver our messages and administer your account. Mobile carriers that transmit the message are bound by their own regulatory obligations.

We keep a record of your opt-out on a suppression list so that we do not message you again. That record exists only to honour your choice.

Marketing

We do not send marketing texts to patients. We may send business marketing emails to provider, insurer and partner contacts about our services, where we have consent or where the soft opt-in under regulation 22 of PECR (or, for contacts in Ireland, regulation 13 of S.I. No. 336 of 2011) applies. Every such message carries an unsubscribe link.

Keep in mind

A text message is not a secure channel. We keep the content of our messages to the minimum needed — we do not include your diagnosis, treatment detail or card details in a text.

8. Sending information outside the UK

Most information stays in the UK or the European Economic Area. Some of our suppliers, including Twilio, are based in or route data through the United States or other countries.

Where information leaves the UK we rely on UK adequacy regulations where they apply, or on the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment and additional technical measures. Where information leaves the EEA we rely on European Commission adequacy decisions or the EU Standard Contractual Clauses, together with a transfer impact assessment. You can ask us for details of the safeguard used for a particular transfer.

9. How we protect it

We hold PCI DSS scope for card data so that it never enters our providers' systems. We encrypt personal information in transit and at rest, restrict access on a least-privilege basis with multi-factor authentication, log access to records, test our systems independently, and train our staff.

We operate an information security management system aligned to ISO/IEC 27001:2022.

10. How long we keep it

Where we act as a processor, the provider's retention instruction governs and may be shorter.

RecordPeriod
Invoice, payment and settlement records7 years from the end of the relevant accounting period, for tax and audit
Claim and remittance data held for a providerFor the term of our agreement with the provider, then returned or deleted on their instruction
Card tokensThe earlier of the card token being disabled or deleted by the card holder, or 7 years
Message content and delivery logs24 months
Opt-out and suppression recordsIndefinitely — we need them to keep honouring your opt-out
Identity and anti-money-laundering records on business customers5 years after the relationship ends
Complaints and disputes6 years from resolution

11. Your rights

You can ask us to give you a copy of your information; correct it; erase it; restrict or object to how we use it; send it to another organisation in a portable format; and withdraw consent where we relied on it. You can object to direct marketing at any time and we will always stop.

Some rights are limited. We cannot delete an invoice we are legally required to keep, and where we act as a processor we must refer your request to your provider.

We will respond within one month. There is no charge unless a request is clearly unfounded or excessive, in which case we may charge a reasonable fee or decline to act, and we will explain why.

If you are unhappy, contact us first. You can also complain to the Information Commissioner's Office — ico.org.uk, 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. If you are based in Ireland, you may also complain to the Data Protection Commission — dataprotection.ie, +353 (0)1 765 0100, 21 Fitzwilliam Square South, Dublin 2, D02 RD28.

12. Cookies

Neither the marketing site at www.privapay.health nor the platform at app.privapay.health sets any cookies.

A signed-in session on the platform is stored in the browser's local storage, not in a cookie. Sidebar open or closed is likewise a local-storage preference on that device and is never sent to our servers. Neither site sets analytics cookies. There is no cookie banner and no cookie settings link.

13. Children

Our services are not directed at children. Where we bill for treatment given to someone under 18, we deal with the parent, guardian or other person responsible for the account, and we do not knowingly collect a child's contact details directly.

14. Changes

We will post any change here and update the version and date above. If a change materially affects how we use your information we will take reasonable steps to notify you, for example by email or by a prominent notice on our website.

This notice was last reviewed on 29 September 2026.