Care Planner Ltd (CarePlanner) understands that your privacy is important to you and that you care about how your Personal Data is used and shared online. We respect and value the privacy of everyone who visits www.care-planner.co.uk (“Our Site”) and will only collect and use Personal Data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Definitions and Interpretation
- In this Policy, the following terms shall have the following meanings:
- “Account” means an account required to access and/or use certain areas and features of Our Site;
- “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
- “Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means Personal Data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
- “We/Us/Our” means Care Plannert Ltd t/a CarePlanner, a limited company registered in England under company number 08274960 whose registered address is 11th Floor Colston Tower, Colston St, Bristol BS1 4XE.
Information About Us
- Our Site is owned and operated by Us.
- Our VAT number is 160733621.
- Our Data Protection Officer is Mark Anslow, and can be contacted by email at firstname.lastname@example.org, or by post at Our registered address.
- We are registered with the Information Commissioner's Office, registration ID ZA301465.
What Does This Policy Cover?
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of Personal Data have been designed to uphold:
- The right to be informed about Our collection and use of Personal Data;
- The right of access to the Personal Data We hold about you (see section 12);
- The right to rectification if any Personal Data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any Personal Data We hold about you (We only hold your Personal Data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your Personal Data;
- The right to data portability (obtaining a copy of your Personal Data to re-use with another service or organisation);
- The right to object to Us using your Personal Data for particular purposes; and
- Rights with respect to automated decision making and profiling.
- If you have any cause for complaint about Our use of your Personal Data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Data Do We Collect?
- business/company name;
- job title;
- contact information such as email addresses and telephone numbers;
- location information such as address and postcodes;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
- communication preferences.
How Do We Use Your Data?
- All Personal Data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your Personal Data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your Personal Data (e.g. by using our Contact Us form), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our products and services to you (please note that We require your Personal Data in order to enter into a contract with you);
- Personalising and tailoring Our products and services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the ‘unsubscribe’ link at the bottom of any bulk email).
- Market research;
- Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
- Tracking and responding to any support requests you may make as a CarePlanner customer.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone or post with information, news and offers on Our products or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You may opt out of this form of communication at any time.
- You have the right to withdraw your consent to Us using your Personal Data at any time, and to request that We delete it. Please note, however, that this may result in us being forced to withdraw our products or services from you.
- We do not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Anonymous Personal Data shared with us for the purposes of website analytics will be retained for 26 months.
- Personal Data submitted to us via the Contact Us form on Our website will be retained for 26 months, unless the Personal Data belongs to an individual whose employer subsequently becomes a customer of CarePlanner, in which case it will be retained in line with the retention schedule in clause 6.5.4.
- Personal Data submitted to us subsequent to a submission of the Contact Us form on Our website, but not directly via the form, will be retained for a period of 26 months, unless the Personal Data belongs to an individual whose employer subsequently becomes a customer of CarePlanner, in which case it will be retained in line with the retention schedule in clause 6.5.4.
- Personal Data shared with us by an individual whose employer becomes a customer of CarePlanner will be retained for the duration of the contract with CarePlanner, plus 26 months. After this time, your Personal Data will be removed from our sales and marketing systems. We may continue to retain support requests and correspondence received from you as part of Our own internal quality assurance processes.
How and Where Do We Store Your Data?
- We only keep your Personal Data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including ensuring the presence of an EU-US Privacy Shield certification and a Data Processing Agreement.
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Steps We take to secure and protect your data include:
- The use of SSL (https) security through Our site;
- The use of cloud-based CRM/ticketing systems with secure, robust data management strategies in place.
Do We Share Your Data?
- We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, mobile telephony services (including handset rental), advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- The third party data processors used by Us and listed below are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any Personal Data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
- HubSpot (HubSpot Inc). Data Processing Agreement in place: https://legal.hubspot.com/dpa; EU-U.S. and Swiss-U.S. Privacy Shield Frameworks certified.
- ZenDesk (ZenDesk Inc). Data Processing Agreement in place, EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
- Google LLC. Data Processing Agreement in place, EU-U.S. Privacy Shield Framework certified.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your Personal Data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in section 4, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving, nor communications that are deemed by Us to be essential to your continued informed and safe usage of Our products or services.
Your Right to Withhold Information
- You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
How Can You Access Your Data?
- You have the right to ask for a copy of any of your Personal Data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com.