Care Esteem Limited, a company registered in England and Wales, with company number 14811558 (we, us or our), understands that protecting your personal data is important. This Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our website and "Care Esteem" mobile application and browser platform (Platform) — collectively referred to as the Services - or when otherwise interacting with you.
It is important that you read this Privacy Policy together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you, so that you understand our privacy practices in relation to your data.
The information we collect
Personal data is information that relates to an identified or identifiable individual.
We may collect, use, store and disclose different kinds of personal data about you, which we have listed below:
- Identity Data including first name, last name and job title.
- Contact Data including billing address, email address and telephone numbers.
- Financial Data including bank account and payment card details (including through third party payment processors that we may engage from time to time).
- Transaction Data including details about payments from you to us and other details of products and services you have purchased from us.
- Technical and Usage Data including internet protocol (IP) address, login data, browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website (including through the use of Internet cookies), the type of browser and operating system you are using, and the domain name of your Internet service provider.
- Profile Data including your username and password for the Platform, purchases or orders you have made, support requests, content you post, send, receive and share through our Platform, preferences, feedback and survey responses.
- Interaction Data including information you provide when you participate in any interactive features of our Services, including surveys and promotions.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties, and your communication preferences.
- Professional Data including, where you are a worker of ours or applying for a role with us, your professional history such as previous positions and experience.
- Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health, genetic and biometric data. We do not actively request special categories of data about you, nor do we collect information about criminal convictions and offences. If at any time we need to collect special categories of data, we will only collect and use it as required or authorised by law.
How we collect personal data
We collect personal data in a variety of ways, including:
- Directly: when you register for an account, through the 'contact us' form on our website, or when you request our assistance via email or telephone.
- Indirectly: while interacting with us, such as when you use our website or the Platform, in emails, over the telephone and in your online enquiries.
- From third parties: such as from your employer where they invite you to access our Services.
- From publicly available sources: such as Companies House and professional networking sites such as LinkedIn.
End User Data
Where your personal data is input into our Services, or where our Services are made available to you through a third party (e.g. a care agency), that business is the 'controller' of any personal data input into the Services (End User Data), and we act as a 'processor' on behalf of the controller. The controller is responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining your consent prior to transferring End User Data to us. End User Data is therefore not covered by this Privacy Policy. You should view the controller's privacy policy and/or contact the controller to understand their privacy practices in relation to your End User Data.
Updating or Correcting End User Data
If you are an end user accessing our Services through a care agency, please note that Care Esteem Limited processes your data on behalf of your agency, which is the data controller. To update, correct, or delete any information within the application, you should contact your agency administrator directly. Care Esteem Limited is unable to make these changes on your behalf.
Purposes and legal bases for processing
We collect and process personal data about you only where we have legal bases for doing so under applicable laws. The table below describes the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We may process your personal data for more than one lawful ground depending on the specific purpose. Please reach out to us if you need further details about the specific legal ground we are relying on where more than one has been set out below.
| Purpose of use / disclosure | Type of Data | Legal Basis for processing |
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| To enable you to access and use our software, including to provide you with a login. |
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| To provide our Services to you. |
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| To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us. |
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| To contact and communicate with you about any enquiries you make with us via our website. |
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| For internal record keeping, administrative, invoicing and billing purposes. |
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| For analytics, market research and business development, including to operate and improve our Services and associated applications. |
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| For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you. |
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| To run promotions, competitions and/or offer additional benefits to you. |
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| If you have applied to work with us; to consider your application. |
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| To comply with our legal obligations or if otherwise required or authorised by law. |
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| To store and make available next-of-kin or emergency contact details for agency users and clients so that care providers can respond appropriately in urgent or life-threatening situations. |
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If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use - though in some cases this may mean no longer using our services.
Please note: where we introduce new processing purposes, we will rely on the appropriate lawful basis under data protection law. This does not automatically require your explicit consent unless consent is the lawful basis. If the change is significant, we will notify you and update this Privacy Policy.
Our disclosures of personal data to third parties
We may disclose personal data to:
- our employees, contractors and/or related entities;
- IT service providers, data storage, web-hosting and server providers such as Amazon Web Services and Microsoft;
- professional advisors, bankers, auditors, our insurers and insurance brokers;
- payment systems operators;
- our existing or potential agents or business partners;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
- any other third parties as required or permitted by law, such as where we receive a summons.
Google Analytics: We have enabled Google Analytics Advertising Features. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. You can opt out of Google Analytics Advertising Features, including by using the Google Analytics Opt-out Browser add-on found here. To opt out of personalised ad delivery on the Google content network, please visit Google's Ads Preferences Manager here, or to opt out permanently install their plugin here. To opt out of interest-based ads on mobile devices, follow the instructions for your device: on Android, open the Google Settings app and select "ads"; on iOS 6 and above, use Apple's advertising identifier (see the settings menu on your device to limit ad tracking).
Overseas transfers
Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom. The level of data protection in countries outside the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws. This includes:
- only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or
- including standard contractual clauses in our agreements with third parties that are overseas.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your rights and choices
Your choice: If you provide personal data to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Privacy Policy. You do not have to provide personal data to us; however, if you do not, it may affect our ability to provide our Services to you.
Information from third parties: If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have that person's consent.
Access, correction, processing and portability: You may request details of the personal data we hold about you and how we process it (a "data subject request"). You may also have a right to have your personal data rectified or deleted, to restrict our processing, to object to automated decision-making, to stop unauthorised transfers, and in some circumstances to have personal data transferred to you or another organisation.
Unsubscribe: To unsubscribe from our email database or opt out of communications (including marketing), please contact us using the details below or use the opt-out facilities provided in the communication.
Withdraw consent: Where we are relying on consent, you have the right to withdraw it at any time. This will not affect the lawfulness of any processing carried out before withdrawal. If you withdraw your consent, we may not be able to provide certain products or services to you.
Complaints: If you wish to make a complaint, please contact us using the details below with full details. We will promptly investigate and respond in writing. You have the right to complain at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Storage and security
We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences and to provide a better user experience. Cookies, by themselves, do not tell us your email address or other personally identifiable information. If you choose to provide our online services with personal data, this data may be linked to the data stored in the cookie. Where required by law, we will always seek your consent before placing any non-essential cookies on your device.
Links to other websites
Our website may contain links to other parties' websites. We do not have control over those websites and we are not responsible for the protection and privacy of any personal data which you provide whilst visiting them. Those websites are not governed by this Privacy Policy.
Use of Google API Services
Distance & Travel Time Calculations. We use Google's API to calculate driving, walking, or transit distances and estimated travel times. To provide this feature, we transmit latitude/longitude coordinates (origin and destination) to Google. Google processes that data in accordance with its Privacy Policy and returns only the distance and duration values. We do not store your raw location coordinates beyond the time needed to complete the request. Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
- We limit our use of the personal data that we collect to providing or improving our Services. We do not use it for any other purposes.
- We only transfer the personal data to others if it is necessary to provide or improve our Services, to comply with applicable law, or as part of a merger, acquisition or sale of assets where we notify you.
- We do not use or transfer the personal data for serving ads, including retargeting, personalised or interest-based advertising.
- These restrictions apply to the raw data we obtain from the restricted scopes and to data that is aggregated, anonymised or derived from them.
We have policies and procedures in place setting out appropriate safeguards for protecting your personal data obtained with the Google APIs, and we ensure that our employees, agents, contractors and successors comply with the Google API Services User Data Policy.
Amendments
We may change this Privacy Notice from time to time. Where the change involves a new processing purpose, we will notify you and identify the lawful basis we rely upon. We will only seek your explicit consent where it is legally required (for example, certain marketing or special category data).
For any questions or notices, please contact Care Esteem Limited (registered in England and Wales, company number 14811558) at [email protected].