Privacy Policy

1. Who We Are

Propelus Ltd

Registered in Scotland:
SC841954

Registered address:
South Church Clinic, Moray Street, Elgin, IV30 1JH

Email:
hello@propelusltd.com

Propelus Ltd is the manufacturer and distributor of the Flex4ward medical device.

2. Information We Collect

We collect information to process orders, provide customer support, and improve our services. This may include:

2.1 Information You Provide Directly

• Name
• Email address
• Phone number
• Billing and shipping address
• Payment details (processed securely by third-party providers; we do not store card information)
• Order history
• Sizing information you provide
• Any information submitted via contact forms or email

2.2 Information Collected Automatically

When you visit our website, we may collect:

• IP address
• Browser type and version
• Device information
• Pages visited and time spent on the site
• Cookies and similar tracking technologies (see Section 8)

2.3 Special Category Data

Flex4ward is a Class I medical device. We do not collect or store medical records or clinical data as a matter of course.

If you voluntarily share information about your health or condition – for example, when asking for sizing guidance – this constitutes ‘special category data’ under UK GDPR. We only process this information where you have given your explicit consent, in line with Article 9(2)(a) UK GDPR, and only for the purpose of responding to your enquiry. It is not stored beyond what is necessary for that purpose, and it is not used for any other purpose without asking you again.

3. How We Use Your Information

We use your information to:

• Process and fulfil orders
• Provide customer service and support
• Manage returns and warranty enquiries
• Improve our website and product offerings
• Send important updates about your order
• Comply with legal and regulatory obligations
• Maintain device safety and traceability requirements under UK medical device regulations

We do not use your data for automated decision-making or profiling.

4. Legal Basis for Processing

Under UK GDPR, we process your data on the following bases:

• Contractual necessity – to process your order and deliver your product
• Legitimate interests – to improve our services and ensure product safety
• Legal obligation – to meet regulatory and tax requirements
• Consent – for optional marketing communications and for special category (health) data you volunteer to us (you may withdraw consent at any time)

How we collect marketing consent: we ask for your consent via an opt-in checkbox at checkout and/or when you sign up to our newsletter. This checkbox is never pre-ticked. Where you are an existing customer, we may also rely on the ‘soft opt-in’ exemption under PECR to contact you about similar products to ones you have previously bought; you can opt out of this at any time using the unsubscribe link in any marketing email.

This section covers consumer (B2C) marketing. Where we contact clinicians and other healthcare professionals in a business capacity – for example, via a work email address, about Flex4ward as a clinical product – this is treated as business-to-business communication and handled under PECR’s corporate subscriber rules, which do not require the same opt-in consent as B2C marketing. Clinicians can still ask us to stop contacting them at any time.

5. Sharing Your Information

We only share your information when necessary and with trusted partners, including:

• Payment processors (our website is built on WooCommerce; payments are processed via our WooCommerce payment gateway)
• Delivery and courier services
• Website hosting and analytics providers
• Professional advisers (e.g., accountants, legal advisers)
• Regulatory authorities if required by law

We do not sell or rent your personal data to third parties.

6. Data Retention

We retain personal data only for as long as necessary:

• Order and transaction records: 6 years (legal requirement)
• Customer service enquiries: typically 12–24 months
• Marketing data: until you withdraw consent
• Device traceability data: retained in line with medical device regulatory requirements

7. Your Rights

Under UK GDPR, you have the right to:

• Access your personal data
• Correct inaccurate information
• Request deletion of your data (where legally permissible)
• Restrict or object to processing
• Withdraw consent for marketing
• Request data portability

To exercise any of these rights, contact us at: hello@propelusltd.com

If you are unhappy with how we have handled your request, or with any other aspect of how we process your personal data, you also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk, or by calling 0303 123 1113.

8. Cookies & Tracking Technologies

Our website uses two categories of cookies:

• Strictly necessary cookies – required for the website to function (for example, the shopping basket and secure checkout). These do not require your consent.
• Non-essential cookies – such as analytics, performance, or advertising/tracking cookies. These are only set with your prior consent.

When you first visit our website, you will see a cookie banner where you can accept or reject non-essential cookies, and choose which categories you consent to. Non-essential cookies are not set until you have given that consent. You can change your cookie preferences at any time via our cookie settings link, or by adjusting your browser settings. Some features may not function properly if you disable strictly necessary cookies.

9. Security

We take data protection seriously and use appropriate technical and organisational measures to safeguard your information, including:

• Encrypted website connections (HTTPS)
• Secure payment processing via third-party providers
• Access controls and data minimisation
• Regular security reviews

No method of transmission is 100% secure, but we work to protect your data to the highest reasonable standard.

10. Children’s Privacy

Flex4ward is not intended for use by children. We do not knowingly collect personal data from individuals under 16.

11. Links to Other Websites

Our website may contain links to external sites. We are not responsible for the privacy practices or content of those websites.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.

13. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact:

Propelus Ltd

Email:
hello@propelusltd.com

Mailing address:
Propelus Ltd
Unit 4
Waterford Circle
Forres
IV36 3EF