Privacy Policy

Positivo Ltd · Last updated: June 2026

1. Who We Are

Monitr is a thyroid monitoring subscription service operated by Positivo Ltd, a company registered in England and Wales. Our registered office is in Sutton, England. References to "we", "us" or "our" in this policy refer to Positivo Ltd.

Laboratory analysis for Monitr subscribers is carried out by Inuvi, our UK-accredited laboratory partner. Blood sample collection devices are manufactured by Tasso Inc. Neither Inuvi nor Tasso are data controllers for your personal data — Positivo Ltd is the sole data controller.

If you have any questions about this policy or how we handle your data, please contact us at: hello@monitr.health

2. What Personal Data We Collect

Waitlist stage (current): When you join the Monitr waitlist, we collect:

• Your email address
• The page URL and form you used to sign up
• UTM parameters from any advertising links you clicked (e.g. utm_source, utm_campaign)
• The date and time of your submission

When Monitr launches (subscription stage): To provide the thyroid monitoring service, we will collect:

• Full name and date of birth
• Delivery address for kit dispatch
• Email address and phone number
• Payment information (processed securely via our payment provider — we do not store card details)
• Health-related data: your thyroid biomarker results (TSH, FT3, FT4, TPO antibodies, TgAb)
• Any information you choose to provide about your symptoms, medications or health history

We also automatically collect device and usage data when you visit monitr.health, including your IP address, browser type, pages visited, and referring website. This is collected via cookies and analytics tools.

3. How We Use Your Personal Data

We use your personal data for the following purposes:

• To operate the Monitr waitlist — sending you updates about the Monitr launch and founding member access
• To provide the subscription service — dispatching your collection kit, processing your sample, delivering your results
• To communicate with you — sending your results, service updates, and any information relevant to your subscription
• To improve our service — analysing how people use Monitr to improve the product
• To comply with legal and regulatory obligations

Your health data (biomarker results) is used solely for the purpose of providing your test results and any associated summaries. We do not use your health data for marketing purposes.

4. Legal Basis for Processing

We process your personal data on the following legal bases under UK GDPR:

• Consent — for waitlist sign-up and marketing communications. You can withdraw consent at any time by unsubscribing or emailing us.
• Contract performance — to fulfil your subscription and deliver the service you've purchased.
• Legitimate interests — for service improvement, fraud prevention, and business analytics, where these don't override your rights.
• Legal obligation — where we are required to process data to comply with applicable law.

Health data is classified as Special Category data under UK GDPR. We process it on the basis of your explicit consent and for the provision of health-related services at your request.

5. Who We Share Your Data With

We share your personal data only where necessary:

• Inuvi — our laboratory partner, who receives your sample and the personal information required to process it (name, date of birth, sample reference)
• Tasso Inc — the manufacturer of our collection device. They do not receive your personal data.
• GoHighLevel (GHL) — our CRM platform, where waitlist and subscriber contact records are stored
• Payment processors — for secure payment handling (when the subscription service launches)
• Royal Mail / postal services — for kit dispatch (name and address only)
• Analytics providers — aggregated, anonymised usage data only

We do not sell your personal data. We do not share your health data with your GP or any other healthcare provider unless you specifically request this.

6. Data Retention

We retain your data for as long as necessary for the purposes set out in this policy:

• Waitlist data — retained until you unsubscribe or request deletion, or for up to 2 years from your sign-up date if no subscription is taken up
• Subscription and health data — retained for 8 years from the end of your subscription, in line with standard healthcare record retention guidelines
• Financial records — retained for 7 years as required by HMRC

7. Your Rights

Under UK GDPR you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — ask us to correct inaccurate data
• Erasure — ask us to delete your data in certain circumstances
• Restriction — ask us to restrict processing of your data
• Portability — receive your data in a machine-readable format
• Object — object to processing based on legitimate interests
• Withdraw consent — at any time where processing is based on consent

To exercise any of these rights, contact us at hello@monitr.health. We will respond within one month. If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

8. Cookies

monitr.health uses cookies and similar tracking technologies for analytics and to improve your experience. By using our site you consent to the use of cookies in accordance with this policy. You can control cookies through your browser settings at any time.

9. Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss or disclosure. All data is transmitted over encrypted connections (HTTPS). Health data is stored securely with access restricted to authorised personnel only.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify waitlist members by email and update the "Last updated" date at the top of this page. Continued use of our service after changes constitutes acceptance of the updated policy.

11. Contact Us

For any privacy-related queries, to exercise your rights, or to make a complaint:

• Email: hello@monitr.health
• Website: monitr.health
• Operated by: Positivo Ltd, England