Care Friends Limited is the controller and is responsible for your personal data (collectively referred to as “CF”, “we”, “us” or “our” in this policy).

Where you are using the App, we are providing this to you on behalf of your employer (our Client). We act as a data processor for our Clients, who use our Services to administer their Employee Referral Scheme. Your employer will be the data controller in respect of most of the personal data you provide when using the App, so we recommend that you read their privacy policy. However we will act as the controller in respect of Technical and Usage Data, on which further information can be found below.

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Name or title of data privacy manager: Emma Melling
• Email address: [email protected]
• Postal address: Antrobus House, 18 College Street, Petersfield, Hampshire GU32 2AH
• Telephone number: 0333 207 4311

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 23 January 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or Services. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our App and Services may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and other third parties. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data: first name, last name and job role.
• Contact Data: email address, telephone number(s) and billing address.
• Technical Data: includes the type of Device you use, mobile network information, your mobile operating system, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology you use to access the Services.
• Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
• Financial Data: includes bank account and payment card details (where appropriate).
• Profile Data: includes your username and password and purchases made by you and feedback you give us.
• Usage Data: includes details of your use of any of the App and Services including, but not limited to, traffic data and other communication data, whether this is required for our own purposes or otherwise.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by filling in forms via the Services, or by corresponding with us (for example, by email, in-app chat, telephone or post). It includes information you provide when you register to use the Services, download the App from the Appstore, create your profile on the Services, share data via the App’s social media functions, and when you report a problem with the App or our Services. If you contact us, we will keep a record of that correspondence.

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

To find out more about the types of lawful basis that we will rely on to process your personal data, please refer to the GLOSSARY section.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

You can manage the in-app notifications that you receive by adjusting your preferences within the App at any time.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share or disclose your information with the following third parties:

• Where you are using the App we may share your information with your Employer, acting as a controller, in order that they can administer the Employee Referral Scheme.
• Service providers acting as processors who provide IT and system administration services to us.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us.
• HM Revenue and Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

All of our data is stored in the UK on servers based in London. Some of our external third party service providers may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide a high level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access the App or the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

As part of the Services you can share jobs via social networking platforms. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

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 to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In relation to the App, we will retain your personal data for as long as we provide access to the App to you, your account remains open or any period set out in any relevant contract your employer has with us. In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data will be deleted.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In certain circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. We may also keep some of your data after your account is closed where it is reasonably necessary to comply with our legal obligations, meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes or enforce our App Terms or Terms and Conditions.

Please note that after your account has been closed your Employer may still have access to information that has been shared with them during your use of the App and the Service. We do not control this data.

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

• Request access to your personal data.

Commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of your personal data.

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data.

This enables you to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(i)     if you want us to establish the data’s accuracy;

(ii)    where our use of the data is unlawful but you do not want us to erase it;

(iii)   where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(iv)   you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer or your personal data.

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Right to withdraw consent.

This applies where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at Eastwood Care Technologies Ltd, Antrobus House, 18 College Street, Petersfield, Hampshire GU32 2AH or [email protected]

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.