Website Privacy Policy

Last updated 1 Oct 2026

Introduction

We are Alto Health. This website is operated by Alto Health Limited, a company registered in Ireland under company number 753717, together with Alto Health UK Ltd, a company registered in Northern Ireland under company number NI724606.


In this Privacy Policy, we will refer to ourselves as ‘we’, ‘us’ or ‘our’. Alto Health Limited and Alto Health UK Ltd are each a controller of the personal information they collect, hold and use about you, as explained in this Policy.


You can get hold of us in any of the following ways:

  • by emailing us at marita@altohealth.io; or

  • by writing to us at Ormeau Labs @ Ormeau Baths, 18 Ormeau Avenue, Belfast, Northern Ireland, BT2 8HS.

We take the privacy and security of the personal information we hold about you seriously. This privacy policy is designed to inform you about how we collect personal information about you and how we use that personal information. You should read this Privacy Policy carefully so that you know and can understand why and how we use the personal information we collect and hold about you.


It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible. If you do not do this, then we may be unable to provide our services to you or respond to your enquiry correctly.


We have appointed Xiao Zhang as our data protection officer. You can contact them using the details set out above.


This Privacy Policy covers personal information we collect through our website and in running our business, for example from customers, prospective customers, suppliers and people who contact us. It does not cover patient or clinical information processed through the Alto platform on behalf of hospitals and healthcare providers. For that information we act as a processor on the hospital’s instructions, and the hospital’s own privacy notice applies.


We may update this Privacy Policy from time to time. This version was last updated on 1/10/2026.


What Personal Data We Collect About You

We may collect the following data about you:

  • Your name

  • Your email address

  • Your address

  • Your phone number

  • Your business name

  • Payment and billing details, if you buy our services

  • Any personal data you post on our website

  • Data about how you use our website

  • Technical data such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website

  • Your marketing and communication preferences

  • Any other information that you directly provide to us whether through our contact form, over the phone, by email or otherwise, such as when entering a competition or completing a survey

The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.


How We May Use Your Data

We will use your data in order to:

  • Process financial transactions to enable you to purchase our products or services

  • Send you customer communications about enhancements to products or services you have bought

  • Enable us to perform a contract with you and process orders, respond to enquiries related to the order and deal with complaints

  • Reply to any enquiries you make about our products or services

  • Send you marketing communications where we are allowed by law to do so

  • Personalize your experience on our websites

  • Monitor the use of our website and online services

  • Ask you to complete surveys or invite you to enter into competitions or prize draws

  • Keep records of orders placed and communications in relation to such orders

  • Keep records of communications

  • Analyse your use of our website and other online services

  • Administer and protect our business and website

  • Deliver relevant website content and advertisements to you

  • Understand the effectiveness of our advertising

  • Bring legal claims against you if you breach a contract or fail to make payment 

  • Comply with any legal obligations we are subject to or as required by a government authority

  • Obtain or maintain insurance policies

  • Manage our business

Our Lawful Ground of Processing

Data protection law in Ireland and the European Union (the EU General Data Protection Regulation (EU) 2016/679 and the Irish Data Protection Act 2018) and, where UK law applies, in the United Kingdom (the UK General Data Protection Regulation and the UK Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025) apply to how we use your personal data. In this Policy we call these “data protection laws”. Under data protection laws, we are only legally able to process your personal data if we have a lawful ground for doing so.


Our lawful grounds of processing are:

  • In relation to Customer Data that we have obtained in relation to you placing an order with us that we hold for the purpose of fulfilling that contract, informing you about updates to the product or service and keeping records of the contract, the processing is necessary for the performance of a contract to which you are subject and for our legitimate interests in informing you about updates to the product or service and to keep records for our business

  • In relation to Prospect Data that we have obtained when you enquired about our products or services (whether that be through our website or otherwise) and that we process in order to reply to your enquiry and keep records of this, the processing is necessary in order to take steps at your request prior to entering into a contract and for our legitimate interests in record keeping for our business

  • In relation to Prospect Data that we have obtained when you signed up for any of our free resources and that we process in order to send you those free resources, reply to your communications about the resources and to keep relevant records, you have given consent to the processing for the purposes of us sending you the free resource and it is in our legitimate interests to reply to your communications and to keep records for our business.

  • In relation to Marketing Data that we have obtained when you told us your marketing preferences, for the purposes of sending you marketing communications, running promotions, delivering relevant website content and advertisements to you and measuring the effectiveness of this advertising, we rely on your consent where the law requires it (for example, marketing emails to individuals who have not bought from or enquired with us, and advertising cookies). Otherwise, the processing is necessary for our legitimate interests, which are to study how customers and users use our products and services, to develop them, to grow our business and to decide our marketing strategy.

  • In relation to User Data that we obtain through cookies and similar technologies on our website, we rely on your consent for cookies that are not strictly necessary, such as advertising cookies and, for visitors in Ireland and the EU, analytics cookies. For strictly necessary cookies, and for other cookies that UK law allows us to use without consent, we rely on our legitimate interests in properly running, securing and administering our website and our business. Please see our Cookie Policy for more detail.

  • In relation to Technical Data (such as your IP address, login data, browser details, pages viewed, length of visit, navigation paths and device settings), we process this data to analyse your use of our website, to administer and protect our business and website, to deliver relevant content and advertisements and to understand the effectiveness of our advertising. Where this data is collected through cookies that need consent, our lawful ground is your consent; otherwise it is our legitimate interests in properly administering our website and business, growing our business and deciding our marketing strategy.

  • In relation to your data that we process in order to comply with legal requirements or as required by a government authority, the processing is necessary for compliance with a legal obligation to which we are subject.

  • In relation to keeping records, this processing is either necessary for compliance with a legal obligation that we are subject to or for our legitimate interests in responsible business operations.


We do not collect any Sensitive Data about you through this website or in running our business. Sensitive data refers to data that 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.


We do not collect any information about criminal convictions and offences.


How We Collect Your Personal Data

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). This includes the personal information that you provide to us when you subscribe to our mailing list, enter a competition or survey. We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy at altohealth.io for more details about this 

We may receive some of your personal data from third parties, including analytics providers,  advertising networks, search information providers, ,and providers of technical and payment services, fraud detection agencies and data brokers or aggregators, some of whom are established outside the EEA.



Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).


Under the Irish ePrivacy Regulations (S.I. No. 336 of 2011) and the UK Privacy and Electronic Communications Regulations 2003 (PECR), we may only send you marketing emails or texts if (i) you bought from us or asked us about our services and we gave you a simple way to opt out, or (ii) you agreed to receive marketing communications, and in each case you have not opted out since. Where the law allows, we may send marketing emails to business email addresses without consent. 


You can opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.


You can ask us or third parties to stop sending you marketing messages at any time by emailing us at marita@altohealth.io. We also have unsubscribe buttons on the bottom of all of our bulk emails.


If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases etc. 


Disclosures Of Your Personal Data 

We may need to share your personal information with other organisations or people. These organisations include:

  • Our group companies: Alto Health Limited and Alto Health UK Ltd share personal information with each other to run our business.

  • Service providers who host our website and systems or provide software, communication and AI services to us, acting on our instructions.

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, accountants, auditors and insurers.

  • Government bodies that require us to report processing activities or otherwise disclose your personal data.

  • Fraud prevention agencies and payment service providers.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

  •  Any organisations that propose to purchase our business and assets, in which case we may disclose your personal information to the potential purchaser.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International transfers


Alto Health Limited is based in Ireland and Alto Health UK Ltd is based in the UK, so personal information may move between Ireland and the UK. Transfers from the EEA to the UK rely on the European Commission’s adequacy decision for the UK, and transfers from the UK to the EEA rely on the UK’s adequacy regulations. Where we transfer your personal information to third parties outside the EEA or the UK, we make sure safeguards are in place to give it a similar degree of protection. As such:

  • We may transfer your personal data to countries that the European Commission (under Article 45 of the EU GDPR) or the UK Government (under UK adequacy regulations) has confirmed provide an adequate level of protection for personal data; or

  • If we use US-based providers that are certified under the EU-US Data Privacy Framework (and, for UK data, its UK Extension), we may transfer data to them on the basis of the European Commission’s adequacy decision of 10 July 2023 and the equivalent UK regulations; or

  • Where we use other service providers established outside the EEA or the UK, we use the standard contractual clauses adopted by the European Commission and, for UK data, the UK International Data Transfer Agreement or the UK Addendum to those clauses, or codes of conduct or certification mechanisms approved under data protection laws.


Data Security

We have put security measures in place to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to employees and partners who need to know it for business purposes. They will only process your personal data on our instructions, and they must keep it confidential.


We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.


Data Retention

We will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. 


When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, Irish and UK law require us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.


In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


Your Legal Rights

Under data protection laws, you have certain rights in relation to your personal information, as follows:

  • Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information that we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.

  • Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.

  • Right to erasure: (this is often called the 'right to be forgotten'). This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.

  • Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.

  • Right to data portability: this right allows you to request us to transfer your personal information to someone else.

  • Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see ”Our lawful ground for Processing” above) and there is something about your particular situation that means that you want to object to us processing your personal information. In certain circumstances, you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing).

  • Automated decisions: we do not make decisions about you based solely on automated processing that produce legal or similarly significant effects for you.


In addition to the rights set out above, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent. 


If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. 


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 or refuse to comply with your request in these circumstances.

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.

We will respond to all legitimate requests within one month. Where your request is particularly complex, or where you have a number of requests, we may extend this period by up to two further months. We will notify you within one month of receiving your request if we need to do so, and will explain the reasons for the delay. 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Data Protection Commissioner (DPC), Ireland’s supervisory authority for data protection issues (https://www.dataprotection.ie/). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.


If you are in the United Kingdom, you can also complain to the Information Commissioner’s Office (ICO) at ico.org.uk. If you live or work in another EU country, you can complain to the data protection authority in that country.

You can make a complaint to us by email to marita@altohealth.io or by writing to us at the addresses above. We will acknowledge your complaint within 30 days and respond without undue delay.


Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy at altohealth.io/cookies

Third-party websites

Our website may contain links to third-party websites. If you click and follow those links, then these will take you to the third-party website. Those third-party websites may collect personal information from you, and you will need to check their privacy notices to understand how your personal information is collected and used by them.