Privacy Policy

PRIVACY POLICY

Updated 02 November 2020

At CareZapp Limited, we know how important privacy is to our customers. We want to make sure you understand how we collect and use your personal information as it might be needed for us to deliver to you our services, products, websites and mobile applications (collectively, our “Services”).

OVERVIEW OF PERSONAL INFORMATION

We collect personal information that you provide directly, information about how you use our services, and information from third-party sources. We use this information to provide you with services, understand the way you use our services so we can improve and personalise your experience, and develop the most relevant apps, technologies, and content for our customers.

WHAT INFORMATION DO WE COLLECT?

Carezapp collects your personal information in a variety of ways.

Information You Provide Directly

Data that is given directly by users when they use Carezapp. This data includes data given by users when they:

• • fill in forms on our Website or Apps, or correspond with us by email, our help centre messenger or otherwise,
  • register to use Carezapp, subscribe to our newsletter, promotional emails or other marketing materials,
  • use Carezapp, or
  • complete any surveys we ask a user to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).

Information Provided of Your Behalf by a Care and/or Support Organisation

Data given about a user (or supported person who may not be a user) by their care provider, family member, healthcare team, or other care and support organisations.

If we collect information from you in connection with a co-branded offer, it will be clear at the point of collection who is collecting the information and whose privacy policy applies. In addition, it will describe any choice options you have regarding the use and/or sharing of your personal data with a co-branded partner, as well as how to exercise those options.

If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, by contacting us as specified in the CONTACT US section of this Privacy Policy.

Information About Your Use of Services

In addition to the information you provide, we may collect information about your use of Carezapp either directly or through third party software tools utilised by Carezapp. We may collect:

• • Device information: hardware model and information, IMEI number and other unique device identifiers, phone number, serial number, current software version, MCC (Mobile Country Code), MNC (Mobile Network Code), MAC address, IP address, cookies, operating system versions, and settings of the devices you use to access Services.
  • Log information: Diagnostic, technical, error, and usage information such as the time and duration of your use of Services, and any information stored in cookies that we have set on your devices.
  • Location information: Your device’s GPS signal or information about nearby Wi-Fi access points and base stations that may be transmitted to us when you use certain Services.

Supplemented Data

We may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyse the accuracy of our records, identify new customers, and provide products and services that may be of interest to you.  If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Third-Party Analytics

Through certain Services, we may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. We may use third-party analytics services on the Services. The service providers that administer these analytics services help us to analyse your use of the Services and improve the Services. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate the use of the Services, help administer the Services, and diagnose technical issues. For example:

Google Analytics, please visit http://www.google.com/analytics/learn/privacy.html and https://www.google.com/policies/privacy/partners.

HOW DO WE USE YOUR INFORMATION?

We use the information we collect for the following purposes:

• • To help you or your device register for our Services
  • To provide a Service or feature you request
  • To provide promotions and offers by way of direct marketing communications, only where you have given us your separate consent
  • To analyse our products and services to help us better understand our customers in order to offer the most relevant communications, services, and experiences to you
  • To ask you for your opinions on our products and services and to carry out customer surveys, with your separate consent if required
  • To provide software updates, maintenance services, and support
  • To comply with the law and legal processes
  • To protect the rights, property, or safety of Carezapp, or any of our affiliates, business partners, or customers.

We use and combine the information we collect about you from our Services, devices, or other sources to provide you with a better experience.

Carezapp processes personal information for the purposes described above. Carezapp’s legal basis to process personal information includes processing:

• • So that we can keep our promises to you, such as providing you with a Service
  • To promote our business interests (for example, to manage our relationship with you and improve your customer service experience), including communications on our website, third-party websites, and online platforms
  • To comply with the law and legal processes
  • With your consent (for example, to send direct marketing communications). If you give consent, you can always revoke it by contacting us as specified in the CONTACT US section of this Privacy Policy.

Carezapp is the data controller of your personal information as described above. For Carezapp customers and for the purposes of providing Carezapp to your care and support groups, Carezapp and you, the Carezapp Customer, act as joint Data Controllers, which means Carezapp and you decide how the data is processed. Carezapp acts as the Data Processor, which means Carezapp is responsible for processing the data. Carezapp and Carezapp’s customers are jointly referred to as (Our, Us) in this privacy policy.

WHO DO WE SHARE YOUR INFORMATION WITH?

We will disclose your information internally within our business, but only to those who need it to further provide Services or to help with your requests.

We will also disclose your information to the following entities, only to the extent that this will be necessary to provide our Services:

• • Affiliates: Other related Group companies which control or own us or we control or own.
  • Service Providers: Carefully selected companies that provide services for or on behalf of us, such as companies that help us with installations, or billing, or that send emails on our behalf. These providers are also committed to protecting your information.
  • Other Parties when Required by Law or as Necessary to Protect Our Services: For example, it may be necessary by law, legal process, or court order from governmental authorities to disclose your information. They may also seek your information from us for the purposes of law enforcement, national security, anti-terrorism, or other issues that are related to public security.
  • Other Parties with Your Consent or at Your Direction: In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.

HOW DO WE KEEP YOUR INFORMATION SECURE?

We take data protection seriously. We’ve put in place physical and technical safeguards to keep the information we collect secure. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

WHERE DO WE SEND YOUR DATA?

Our servers are located in the UK and the EU, your use of our Services may also involve the transfer, storage, and processing of your personal information to other countries; such countries include, without limitation, countries in the European Economic Area, the United Kingdom, and the United States of America. We will take appropriate measures, in compliance with applicable law, to ensure that your personal information remains protected according to this Privacy Policy.

WHAT ARE YOUR RIGHTS?

Your personal information belongs to you. You can ask us to provide details about what we’ve collected, and you can ask us to delete it or correct any inaccuracies. You can also ask us to restrict or limit the processing, sharing, or transfer of your personal information, as well as to provide to you the personal information that we’ve collected so you can use it for your own purposes. However, requesting the deletion of your personal information may also result in a loss of access to Services we provide. We won’t delete data that we’re required by law to retain.

To make a request concerning your rights or to make an inquiry, contact us. See the CONTACT US section.

HOW LONG DO WE KEEP YOUR INFORMATION?

We won’t keep your personal information for longer than is necessary for the purpose for which it was collected. This means that information will be destroyed or erased from our systems when it’s no longer required.

We take appropriate steps to ensure that we process and retain information about you based on the following logic:

1. 1. At least the duration for which the information is used to provide you with a service
   2. As required under law, a contract, or with regard to our statutory obligations
   3. Only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or for statistical purposes, subject to appropriate safeguards.

WHAT THIRD-PARTY SERVICES DO WE USE?

Some of the content and functionality in our Services is provided by third parties, in particular, to capture Internet of Things data, to host the Carezapp platform, capture analytics, and communicate with a user. These third parties may use cookies, beacons, tracking pixels, and other tools to collect information about your use of these Services. These third parties are not controlled directly by Carezapp, so we recommend that you check their privacy policies to understand how they use your data.

Amazon Web Services (AWS) – https://aws.amazon.com/compliance/data-privacy-faq/

Intercom – https://www.intercom.com/legal/privacy

Samsung SmartThings – https://www.smartthings.com/uk/privacy

AGE RESTRICTIONS

Our Services are available for purchase only for those over the age of 18.  Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us.

CHANGES IN OUR PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

CONTACT US

You can contact us to update your preferences, correct your information, submit a request, or ask us questions.

The easiest way is through the Contact Us section of https://live-carezapp.pantheonsite.io/contact/.

You can also contact us at:

Data Controller, Carezapp Ltd, C/O Century House, Harold’s Cross Rd, Harold’s Cross, Dublin, D6W P993, Ireland.

Data Controller, Carezapp Ltd, C/O Vidatec, First Floor, Innovation House, 17 Luna Place, Dundee DD2 1TP, United Kingdom.

You can lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal information infringes applicable law. Contact details for all EU supervisory authorities can be found at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.