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Privacy Policy

Last updated: 25th March 2026

1. Introduction

This Privacy Policy explains how Consenta (“we”, “us”, “our”) collects, uses, discloses and protects personal data when individuals use our websites, applications, platforms and related services (together, the “Services”).

Consenta is a technology platform that provides consent management, data anonymisation and data aggregation services to organisations that handle clinical, health-related and lifestyle information. It helps those organisations record, manage and evidence individuals' permissions for the use of their data, apply privacy-enhancing techniques, and support compliant reuse of data for purposes such as care delivery, operations, analytics and research.

This Policy also explains how we comply with the UK General Data Protection Regulation (“UK GDPR”), the EU General Data Protection Regulation (“EU GDPR”) and, where applicable, the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

2. Who we are and contact details

Controller: Manorath LLC (trading as “Consenta”)

Registered address: Delaware, USA.

Privacy contact / Data Protection Officer: Manjinder Virk

Email: Info@Consenta-global.com

3. Scope of this Policy

This Policy applies when:

  • You visit or use our websites, portals or applications.
  • You interact with us as a customer, supplier, partner or prospective customer.
  • Your personal data is processed within our platform on behalf of our customers (for example, healthcare providers, laboratories, research organisations or life-science companies).

When we process personal data on behalf of our customers, we generally act as a “processor” or “business associate” and our customer remains responsible for providing appropriate privacy information to individuals.

4. Categories of personal data we process

We may process the following types of personal data, depending on how you interact with us:

Identification and contact data — Names, email addresses, postal address, telephone numbers, job title, employer or organisation.

Account and usage data — Usernames, login details (hashed), account settings, support queries, activity logs, audit trails and similar information relating to your use of the Services.

Clinical and lifestyle data — Health-related data, laboratory data, demographic information and lifestyle data that are provided to us by our customers or directly by you, where this is necessary for the purpose of the Services and permitted by law.

Consent and preference data — Records of consent and permissions, including consent wording, policy versions, scope, timestamps, revocations, and other preference information, where relevant.

Technical and device data — IP address, device identifiers, browser type, operating system, referral URLs, pages viewed, and the dates and times of visits and interactions with our Services.

We do not intentionally collect information from children without appropriate authorisation from a parent, guardian or relevant organisation.

5. How we obtain personal data

We collect personal data in the following ways:

Directly from you — When you create an account, complete forms, contact us, participate in a pilot or trial, or otherwise communicate with us.

From our customers and partners — When organisations (such as healthcare providers, laboratories, research institutions or commercial partners) provide data to us in order for us to deliver the Services to them.

Automatically — Through the use of cookies, SDKs, pixels and similar technologies when you visit or use our websites or applications.

6. Legal bases for processing (UK/EU GDPR)

Where the UK GDPR or EU GDPR applies, we rely on one or more of the following legal bases:

Consent (Article 6(1)(a), Article 9(2)(a)) — For certain activities, particularly the processing of special category data such as health information, where explicit consent is required.

Performance of a contract (Article 6(1)(b)) — To provide, maintain and support our Services, including setting up accounts, responding to support requests and fulfilling our contractual obligations.

Legal obligation (Article 6(1)(c)) — To comply with applicable laws and regulations, including record-keeping, regulatory reporting and responses to lawful requests.

Legitimate interests (Article 6(1)(f)) — To operate, secure and improve our Services, prevent fraud and misuse, manage our business, and communicate with you about updates or similar information, provided that these interests are not overridden by your rights and freedoms.

Where we process special category data, such as health data, we rely on an additional condition under Article 9 GDPR, for example explicit consent, processing for the provision of health or social care under professional secrecy, or processing for scientific research in accordance with applicable safeguards and local laws.

7. HIPAA context (where applicable)

For certain US-based customers that are subject to HIPAA, we may act as a “Business Associate” in relation to Protected Health Information (“PHI”). In those cases:

  • We enter into Business Associate Agreements (“BAAs”) with our customers as required by HIPAA.
  • We use, disclose and safeguard PHI only as permitted by the BAA and HIPAA, including the Privacy Rule and Security Rule.
  • We implement physical, administrative and technical safeguards designed to protect PHI against unauthorised access, use or disclosure.
  • We do not use PHI for our own independent marketing or unrelated purposes without appropriate authorisation.

8. Purposes for which we use personal data

We use personal data for the following purposes:

To provide and operate the Services — Operating our consent, data management, anonymisation and aggregation features; enabling users to access and use the platform; maintaining user accounts and preferences.

To manage consent and permissions — Capturing, storing and updating records of consent and permissions associated with particular datasets and use cases, and enabling customers to audit such records.

To support analytics, research and product development — Where lawful and subject to appropriate safeguards, using de-identified, pseudonymised or aggregated data to analyse usage, improve our Services and support research and innovation.

To provide support and communicate with you — Responding to enquiries, providing customer support, sending administrative messages, service announcements and security alerts.

To ensure security and prevent misuse — Protecting our Services and users against fraud, abuse and security incidents; monitoring, investigating and mitigating suspicious activity.

To comply with legal and regulatory requirements — Meeting obligations under applicable laws, regulations, codes of practice and professional standards, and responding to lawful requests by public authorities.

9. Data minimisation, pseudonymisation and anonymisation

We apply a privacy-by-design and privacy-by-default approach, including:

  • Limiting personal data collection to what is necessary for the specified purposes.
  • Using pseudonymisation, hashing and other techniques to separate identifiers from data where appropriate.
  • Anonymising or aggregating data where possible so that individuals are no longer identifiable, especially for analytics, statistics and research.

10. Sharing and disclosure of personal data

We may share personal data with:

Customers and their authorised users — Where our platform processes data on behalf of a customer, data is made available to that customer and its authorised personnel in accordance with our contracts with them.

Service providers and processors — Third-party vendors that provide hosting, infrastructure, security, analytics, communication tools, customer support and other services necessary for us to deliver the Services. These parties act on our instructions and are subject to contractual obligations of confidentiality and data protection.

Professional advisers — Legal, accounting, insurance and other advisers bound by confidentiality obligations, where necessary for the operation of our business.

Authorities and third parties — Where required by law or reasonably necessary to protect the rights, safety or property of us, our users or others, we may disclose information to regulators, law enforcement or other competent authorities.

We do not sell personal data.

11. International data transfers

Personal data may be transferred and processed in countries outside the UK or European Economic Area (“EEA”), including countries that may have different data-protection laws. Where we transfer personal data internationally, we will ensure that appropriate safeguards are in place, such as:

  • An adequacy decision by the European Commission or UK government.
  • Standard contractual clauses approved by the European Commission or UK authorities, together with any necessary supplementary measures.
  • Other safeguards permitted by applicable data-protection laws.

You may contact us for more information about the specific safeguards in place for international transfers.

12. Data retention

We retain personal data only for as long as reasonably necessary to fulfil the purposes described in this Policy, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

When it is no longer necessary to retain personal data, we will delete or anonymise it, or if this is not possible (for example, because it is stored in backup archives), we will securely store the data and isolate it from any further processing until deletion is possible.

13. Your rights (UK/EU)

Where the UK GDPR or EU GDPR applies, you may have the following rights in relation to your personal data, subject to certain conditions and exemptions:

  • Right of access — To obtain confirmation as to whether we process your personal data and, if so, to receive a copy of that data.
  • Right to rectification — To request correction of inaccurate or incomplete personal data.
  • Right to erasure — To request deletion of your personal data in certain circumstances.
  • Right to restriction of processing — To request that we limit the processing of your personal data in specific situations.
  • Right to object — To object to processing carried out on the basis of legitimate interests, and to direct marketing at any time.
  • Right to data portability — To receive personal data that you have provided to us in a structured, commonly used and machine-readable format, and to request that it be transmitted to another controller, where technically feasible.

Where we process personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before consent was withdrawn.

If we process your data on behalf of a customer, you may need to exercise your rights directly with that customer. We will support our customers in responding to such requests where required by law and our contracts.

14. How to exercise your rights or contact us

To exercise your rights or ask questions about this Policy, please contact us using the details in section 2.

You also have the right to lodge a complaint with your local supervisory authority, for example:

  • In the UK: the Information Commissioner's Office (ICO).
  • In the EU: your local data protection authority.

15. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction or damage.

These measures may include access controls, encryption, network and application security, logging and monitoring, staff training and internal policies, and regular review of our security posture.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will take appropriate steps to inform you, which may include a notice on our website or direct communication.

The “Last updated” date at the top of this Policy indicates when it was most recently revised.

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