Who we are

Nul Health Limited (“Nul”) offers clinically proven alcohol reduction treatment to support your goals. Nul helps you change your relationship with alcohol - whether you want to cut back or quit entirely.

We are registered in England and Wales with Companies House, and we are also registered with the UK Information Commissioner’s Office.

Our registration details are below, and you can find the Contact Details of our Data Protection contact in the Contacting Us section of this page.

Company Name: Nul Health Limited
Registration Number: 16119526
Registered Address: 3rd Floor, 86-90 Paul Street, London, EC2A 4NE
ICO Registration Number: ZB867166

Contacting Us

If you have any questions about our privacy notice, our use of personal data, or if you wish to exercise your rights in respect to your personal information, please contact our Data Protection contact using the details below.

Data Protection contact: Matthew De Jesus
Email: hello@choosenul.com
Telephone: 07870127247
Post: Data Protection contact Nul Health Limited, 3rd Floor, 86-90 Paul Street, London, EC2A 4NE
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ICO Registration Number: ZB867166

Your information

Your information may come to us from a number of different sources. You may provide it directly to us or via a client organisation when accessing or using our services; it may be generated in the course of using those services, or it may be publicly available information.

Information may be provided directly by you in some of the following circumstances

• You register as a service user on our platform directly with us or via one of our client organisations
• You complete a form on our website or platform
• You create an account on our platform
• You contact us to request support, give feedback, or make a complaint
• You send us information as part of ongoing service delivery
• You sign up to a mailing list or automated communication from us

Other examples of where Nul obtain your personal data include

• When you visit our website or log into our platform, e.g. via cookies on our website
• By accessing your publicly available contact details online, e.g. to contact you about a service of interest
• When an account is set up for you by another member of your team or organisation

Note: Where personal data is provided to us by a third party, we will make sure that these third parties have provided you with appropriate privacy information on the sharing of this data with Nul and have a clear lawful reason for sharing this data.

Where this is found not to be the case, we will make every effort to make sure you are aware that we are processing this information within a month. Where contacting you directly in relation to this is difficult to achieve, then we will ensure that our privacy notices clearly detail where this is happening.

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this notice.

More information on our current uses of data from different sources are detailed below.

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Using Your Information

This section describes how we use your information. Each purpose is described below with detail relating to:

Purpose
‍Why we collect this information

Information
‍What we collect – what personal and potentially more sensitive data we collect for this purpose

Source
‍The source of this data – was this provided by you or obtained from another source

Legal Basis
‍Our legal justification for using this data – what lawful basis Nul has under the UK General Data Protection Regulation and Data Protection Act 2018 for using your data in this way

When using our services

• Purpose - in order for Nul to operate a platform and service provided to you directly or via a client organisation.
• Information - name, date of birth, address, and contact details for potential and actual service users.
• Source - provided by potential or actual service users directly (e.g. during an onboarding call), or from other organisations such as a client organisations.

This may be obtained in-person, via email, telephone, video call, or entered directly into our platform by the service user or by a system, organisation administrator, or client organisation (including via API). 

• Legal Basis - for the performance of a contract or to take steps to enter into a contract with you and with your explicit consent in relation to special categories health information.

Liaising with other care providers/professionals

• Purpose  - in order for Nul to share information with your GP, other health & care professionals and family members, to enable effective delivery of the service provided to the individual.
• Information - name and contact details of other healthcare professionals in the care pathway and information on their role within a specific pathway or service. Name and contact details of paid or professional carers, family members and other individuals within the informal support network as required.
• Source - provided by the service user, from the client organisations and their team members. From other healthcare professionals in the care pathway or from other paid/professional carers, family members or other members of the informal support network.

This may be obtained in-person, via email, telephone, video call, or entered directly into our platform by the service user or by a system, organisation administrator, or client organisation (including via API).

• Legal Basis - as part of the legitimate interests of Nul in delivering appropriate services either directly or under contract with the client organisation.

Liaising with client and other partner organisations

• Purpose - in order to deliver the appropriate services under contract to the client organisation and to liaise with organisations working on specific programmes of work including project partners and platform integration partners.
• Information - name, email address, roles, and any other info provided by them.
• Source - directly from individuals within the client/partner organisations via email, telephone, video call, or entered into our platforms themselves or by a system or organisation administrator (including via API).
• Legal Basis - for the performance of a contract or to take steps to enter into a contract with the client organisation.

Communicating with potential clients

• Purpose - in order to effectively discuss procurement and decisions about our products and services with potential clients.
• Information - name, role, and email address of potential clients and any further information provided directly via email, telephone, video-call, and in person communications.
• Source - available via publicly accessible sources including websites, membership lists, and social media profiles. Provided directly by the potential client via email, telephone, video call, or during an in-person interview.
• Legal Basis - as part of the legitimate interests of Nul in promoting their organisation and services to new clients.

Communications and providing information on our work

• Purpose - to send you email notifications you have specifically requested in relation to Nul’s services and communications such as newsletters and bulletins. To send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications).
• Information - email address, job title, organisation name, consent status for receiving marketing materials.
• Source - provided by you as part of accessing Nul’s services or attending Nul’s events.
• Legal Basis - as part of the legitimate interests of Nul where information is sent in paper form, carried out in a way that balances the rights and interests of individuals against the legitimate interests of Nul. Based on explicit consent provided by you for this information to be sent to you in electronic form.

Carrying out user or market research

• Purpose - to fully understand the current market and the effectiveness of solutions and services being delivered.
• Information - name, contact details, and any additional information you provide to us through surveys, interviews or other communications, including demographic information such as your age and sensitive information such as your medical history.
• Source - provided directly by you as part of participating in this research via email, telephone, video call, or an in-person interview.
• Legal Basis - as part of the legitimate interests of Nul where gathering views of staff and with explicit consent for research involving members of the public and service users and wherever more sensitive special categories data is processed. Also for archiving purposes for research that is maintained for historical and statistical purposes (anonymised wherever appropriate).

Dealing with your enquiry or a complaint

• Purpose - to allow Nul to effectively deal with any enquiry or complaint you or others may have.
• Information - name, contact email, and telephone number and nature of the enquiry or complaint. Personal data of complainants and respondents.
• Source - provided by you and others via our website, social media channels, telephone, or in writing. Potentially provided by another organisation that we have contacted about a complaint you have made and who gives us your personal information in its response or a complainant may refer to you in their complaint correspondence.
• Legal Basis - as part of the legitimate interests of Nul. This will only be carried out in a way that balances the rights and interests of individuals against the legitimate interests of Nul.

Dealing with rights of data subject requests

• Purpose - to allow Nul to respond to requests under the Data Protection Act for individuals to exercise their rights, e.g. to access their own data, request erasure of data, object to processing, etc.
• Information - name, contact email, and telephone number, nature of data subject request and proof of ID where required to verify your identity.
• Source - provided by you via our website, social media channels, via email, telephone, or in writing.
• Legal Basis - Nul are legally obliged under the Data Protection Act to respond to data subject requests.

Managing data breaches

• Purpose - to be able to assess any impact on individuals of a data breach involving personal data held on Nul systems or on third party systems.
• Information - any information relating to an individual that may have been breached.
• Source - from any organisation or individual that may have reported this data breach to Nul.
• Legal Basis - Nul are legally required under the Data Protection Act to respond to data breaches appropriately.

Prevention of crime and dishonesty

• Purpose -Nul may use personal data to protect the public against identity theft, piracy, money laundering, or fraud. It may also need to share personal data with the police or other law enforcement body as part of crime reporting or supporting a police investigation or to support anti-money laundering or anti-terrorism activities.
• Information - any information relating to an individual involved in the specific criminal investigation or act.
• Source -provided by staff, suppliers, or clients as part of their ongoing relationship with Nul.
• Legal Basis - under the legitimate interests of Nul to support ongoing investigation, under substantial public interest requirements in responding to crime and dishonesty and in some cases with explicit consent, where this consent would not prejudice the outcome of any investigation.

Supplier management

• Purpose - to ensure appropriate financial management of ongoing contracts with Nul suppliers including sending statements, invoices, and payment reminders to you, and collecting payments from you.
• Information - suppliers name, email, contact numbers, and financial documentation such as purchase order, invoices, etc.
• Source - provided by the supplier organisation or generated by Nul.
• Legal Basis - in order to manage the ongoing contract with that supplier.

Recruitment and staff management

• Purpose - to manage recruitment and appropriate management of staff employment contracts including to pay staff, administer relevant benefits, pensions and insurance entitlements, meet legal obligations under relevant employment related laws, keeping employment records, manage sickness/absence and appropriate performance and disciplinary/grievance processes, carrying out DBS checks where required, to meet disability law requirements and to support diversity monitoring, provide references and support occupational health requirements including counselling. To identify health information required for insurance purposes for staff and potentially their family members.
• Information - potential applicant’s name, contact details, employment history, and other information from the applicant’s CV or profile visible or sent to us. Information provided and assessments completed as part of the application process and feedback about you from our team and your references. General information (Employee Number, Department, Role, Start Date), PAYE Info, Personal Details, Bank Details, Emergency Contacts, Medical Info, and Right to Work in UK.
• Source - provided by the member of staff directly or via recruitment agencies where recruited in this way. From publicly accessible sources including websites, job boards, and social media profiles.
• Legal Basis - in order to manage the ongoing employment contract with the staff member, to meet legal obligations in relation to employment law and health and safety, as part of the legitimate interests of Nul in recruiting relevant staff to their organisation, under substantial public interest for insurance purposes and with explicit consent for occupational health purposes.

Improving the use of our website and IT systems

• Purpose - to ensure appropriate system administration and troubleshooting of website issues, to improve the quality of the site and to personalise the website experience. To keep track of and solve issues users are experiencing with our technology systems, personalising our website for you, enabling your use of the services available on our website, keeping our website secure and preventing fraud.
• Information - user’s IP Address or the location of your computer or network on the Internet and any individual’s data needed to deal with an internal system issue (where the issue is linked to that individual’s data).
• Source - automatically collected as part of using our website and via cookies on the website (see Cookies and our Website section here) and identified by Nul in managing specific IT issues.

LegalBasis - at the current time, only essential cookies are used based on the legitimate interest of Nul to manage its website effectively. Should this change in the future, explicit consent will be sought for use of cookies when you access our website. Methods of turning off cookies can be found in our Cookies Policy section here. Ensuring our systems are working effectively and user issues can be resolved is part of our legitimate interests in running the organisation effectively.

Processing Sensitive Data

Nul may need to process sensitive special categories data as part of delivering our services to you or that you may provide voluntarily as part of service user or market research or as a member of staff.

Note: this information is only ever processed where there is a clear legal basis to do so as described above. We will only ever process the minimum amount of sensitive data in order to achieve the purposes set out within this privacy policy.

Processing Personal Data

Nul are committed to only collecting the minimum personal data required in order to achieve the purposes highlighted above.

We continually review our data collection practices ensuring this continues to be the case and to ensure that data is deleted when no longer required for the specified purposes.

Disclosing Your Data

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as is reasonably necessary for the purposes set out in this notice and where there is a clear lawful reason for doing so.

We may share your data with third parties to perform services on your behalf.

• Types of third parties who may have access to your personal data include: 
  
  • Healthcare professionals involved in your care pathway
  • Third Party IT System Suppliers who may host your data on their systems and may need some level of access to resolve technical concerns
  • Solicitors, counsel, and claimants in relation to legal matters
  • Accountants in relation to finance matters
  • Purchasers/investors whom we may choose to sell, transfer or merge parts of our business or our assets or who are stakeholders or investors in our business

We may disclose your personal information

• Reasons we may disclose your information: 
  • To the extent that we are required to do by law and regulatory requirements
  • In connection with any ongoing or prospective legal proceedings
  • In order to establish, exercise, or defend our legal rights (including providing information to others for the purpose of fraud prevention and reducing credit risk)
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such an authority would be reasonably likely to order disclosure of that personal information
  • To ensure that adult and children’s safeguarding matters are managed appropriately, where it’s legally required for the safety of the individuals concerned
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We will never sell or share your personal information with other organisations for their direct marketing purposes without your explicit consent. Except as provided in this policy, we will not provide your personal information to other third parties.

Transferring Data Outside the UK

Personal data is currently only transferred within the United Kingdom, where data protection laws have been assessed as adequate to ensure the necessary protections needed for this personal data.

Note:  should Nul ever need to transfer personal information you submit to us to countries or jurisdictions outside the UK, we will ensure that our suppliers provide adequate protection for the confidentiality and security of this information and the rights of data individuals in connection to the transfer of their personal data.

Specific safeguards will exist to govern this sharing, including carrying out appropriate risk assessments around this transfer and ensuring that these countries have adequate data protection provisions in place as agreed by the Information Commissioner’s Office or other additional safeguards are in place, most commonly implementing standard contractual clauses agreed by the European Data Protection Board and/or the ICO for international transfers within their contracts.

Security of Your Data

Nul is committed to processing and retaining data within established technological and physical controls in a transparent manner, as well as promoting and safeguarding the information rights of data subjects.

Nul implements appropriate technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction. Any such procedures will be reviewed as necessary and updated to ensure their effectiveness in line with advances in technology.

Note: whilst we have done everything we can to ensure security of data sent using our systems, any transmission of data is done so at your risk. While we strive to protect your information, no method of transmission over the internet is completely secure.

How Long We Keep Your Data For

Personal data that we process for any purpose will not be kept for longer than is necessary for that purpose.

Different purposes will have different retention periods, and we will (for example) retain data about financial records longer than we would retain information for general enquiries.

Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

Notwithstanding the other provisions of this section, we will retain your personal data as below:

• To the extent that we are required to do so by law
• If we believe that the information may be relevant to any ongoing or prospective legal proceedings
• In order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)
• To support the ongoing business purposes of Nul as specified above (with due consideration for the rights and freedoms of individuals’ privacy)

If you would like further details of how your personal data is retained by Nul, please contact us directly.

Your Rights

You have a number of rights under Data Protection law. Full information on your rights under the Data Protection Act can be found on the ICO Website. These include:

• The right to be informed about the collection and use of your personal data, e.g. via this privacy notice
• The right to access your personal data
• The right to have any inaccurate personal data rectified, or completed if it is incomplete
• The right to have your personal data erased in certain circumstances
• The right to request the restriction or suppression of your personal data in certain circumstances
• The right to data portability – to obtain and reuse your personal data for your own purposes across different services
• The right to object to our use of your information in certain circumstances, e.g. for marketing or profiling purposes

Accessing Your Information

If you would like to access your own personal information or exercise any of the rights detailed above, please contact us using the details below.

In the majority of cases, we will respond to your request within one month of receiving the necessary information required to deal with your request. We may ask you to supply appropriate evidence of your identity and any additional information to help us to deal with your request effectively.

Note: there may be some exemptions to dealing with your rights as specified in Data Protection law, but we will ensure you are fully informed of this within a month of receiving your request.

Objecting to Our Use of Your Information

If you would like to object to marketing or any other uses of your data, please contact us using the details below.

You can object to our use of your information in certain circumstances, such as for profiling and for marketing purposes.

You can unsubscribe to receiving marketing materials from Nul at any time, and we will ensure that you are given the opportunity to opt out of receiving this type of information whenever we contact you in this way.

Raising A Concern If Your Rights Are Not Met

If you are unhappy about the use of your personal data, please contact us using the details below, and we will work to resolve your concern.

If you have a concern that cannot be resolved through discussion with us, this can also be raised with the Information Commissioner’s Office. More information can be found on the ICO website.

Profiling

Nul do not carry out any automated individual decision making about individuals.

We may develop profiles based on your usage which will help inform future interventions and required changes to your treatment. This helps your support network to improve the overall effectiveness of your treatment, as well as to provide you with better, more personalised care.

Note: the UK General Data Protection Regulation includes certain provisions around how personal data can be used for Profiling (where personal data is processed to evaluate certain things about an individual) and Automated individual decision making (where a decision is made based on your personal data solely by automated means). This includes ensuring that individuals are made aware of this profiling, how decisions are made based on this, and the consequences of these decisions.

Cookies and Our Websites

Our website (www.choosenul.com) is owned and operated by Nul. Our website includes hyperlinks to, and details of, third party websites over which we have no control. We are not responsible for the privacy policies and practices of these third parties.

Nul uses cookies and similar technologies to enhance your experience on our website. For detailed information on how we use cookies and how you can manage your preferences, please refer to our Cookie Policy here.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Different versions of this privacy notice

The information provided within this privacy notice can be made available in different formats including in printed form, different languages, child-friendly notices, and approaches that meet the needs of the visually- and hearing-impaired.

Should you require this information in a different format, please contact the Data Protection contact.

Changes to our privacy notice

Nul may update this Privacy Policy from time to time, should any new types of processing be identified, or changes to current data protection legislation may mean changes are required. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically to stay informed about how we are protecting your data

Last Updated 12th August 2025 by Matthew De Jesus