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Privacy Notice

Welcome to Care Companion's privacy notice.

Care Companion is a website operated by the University of Warwick who respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we use and look after your personal data when you visit Care Companion and tell you about your privacy rights.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how the University of Warwick collects and processes your personal data through your use of Care Companion, including any data you may provide when registering with the site as well as when using Care Companion.

It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.

Data CONTROLLER

The University of Warwick is the data controller and responsible for your personal data (collectively referred to as "Warwick", "we", "us" or "our" in this privacy notice).

Warwick’s Data Protection Officer (DPO) is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

DPO CONTACT DETAILS

A Bajaj
Information and Data Director
Data Protection Officer
University of Warwick
University House
CV4 8UW

Infocompliance@warwick.ac.uk

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 www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact the DPO in the first instance.

CHANGES TO THIS PRIVACY NOTICE 

We keep our privacy notice under regular review and this version was last updated on 1st April 2018

THIRD-PARTY LINKS

This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

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 which we have grouped together as follows:

  • Personal details includes your first name and last name.
  • Contact details includes your email address, post code and telephone number.
  • Technical details includes 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 on the devices you use to access the Care Companion website.
  • Profile details includes your email address and password and all information that you add when creating your profile and any content that you create when using Care Companion such as your mood monitor, your preferences, your journal entries and your to do lists.
  • Usage Data includes information about how you use the Care Companion website.
  • Preference details includes your preferences in receiving communications from us in relation to participation in research and surveys.
  • Third Party Data includes any data you provide about another person whilst using Care Companion. For example information about the person you are caring for like their name, what they like to be known as or any health-related information. You may also add third party information into the address book when creating a new contact. It is likely that the third party data you provide whilst using Care Companion will include Special Category personal data as it relates to the health of the person you are caring for. Please refer to the Terms of Care Companion in relation to your responsibilities about third party data. 

We also collect, use and share Anonymised Data such as statistical or demographic data. This data will be derived from your personal data but will be anonymised and 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 website feature.

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.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Personal, Contact, Profile and Third Party Data by registering with Care Companion and completing the ‘Let’s get started’ section of the website. You may also give us this type of data by corresponding with us by the ‘Contact us’ form or via email. This includes personal data you provide when you:
    • register on the Care Companion website;
    • complete the contact us form on the Care Companion website;
    • interact with the functionality on Care Companion such as journal entries;
    • send us an email;
    • fill out information in relation to the person you are caring for;
    • provide feedback; or
    • agree to participate in research.
  • Automated technologies or interactions. As you interact with the Care Companion website, we may automatically collect Technical details about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our T&C’s for further details.

​4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Please click here to find out more about the types of lawful basis that organisations can rely on to process personal data.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our DPO if you need any further details about the specific legal ground we are relying on to process your personal data.  
 

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new user of Care Companion and maintain your account including communicating with your via email about any inactivity and closing your account.

  • Identity
  • Contact
  • Profile
  • Usage
  • Technical

Necessary for the performance of a contract (Ts&Cs) with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms, privacy notice or features on Care Companion;

(b) Asking you to provide feedback on Care Companion.

  • Identity
  • Contact
  • Profile
  • Preference

Necessary for the performance of a contract (Ts&Cs) with you

 

Necessary to comply with a legal obligation

 

Necessary for our legitimate interests (to keep our records updated and to study how customers use Care Companion)

To invite you to partake in research or surveys via email

  • Identity
  • Contact
  • Profile
  • Usage
  • Preference

Consent

To invite you to partake in research or surveys via notifications on through the Care Companion website

  • Identity
  • Contact
  • Profile
  • Usage
  • Preference

Necessary for our legitimate interests (to study how customers use and benefit from Care Companion)

 

To administer and protect Care Companion (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Identity
  • Contact
  • Technical

Necessary for the performance of a contract (Ts&Cs) with you

 

Necessary to comply with a legal obligation

To make suggestions and recommendations to you about resources or contacts in the address book that may be of interest to you

  • Identity
  • Contact
  • Profile
  • Usage
  • Preference
  • Technical
  • Third party

Consent

To use data analytics to improve Care Companion, customer relationships and experiences

  • Technical
  • Usage

Necessary for the performance of a contract (Ts&Cs) with you

 
RESEARCH

We strive to provide you with choices regarding certain personal data uses, particularly around research. As mentioned above, the University of Warwick may use your data collected and provided through Care Companion in an aggregated, anonymised format for the purposes of understanding how Care Companion is used in order to inform the future development of the site and for the purposes of research that may be published in peer-reviewed scientific journals.

You may also be invited, through direct emails as well as notifications on the Care Companion website, to participate in a number of research-based activities and feedback. Participation in this research does not form part of the Terms and Conditions of the Care Companion website and is completely voluntary and on an opt-in consent basis. Any research will be conducted according to standards and protocols agreed by the University of Warwick and/or NHS research ethics committees, and will be undertaken in ways that ensure that any reports or publications cannot be linked to any particular individual and their personal data.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Terms of Use.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it. If we decide we want to use your personal data for a different purpose then we will contact you, notifying you of our intended new purpose and on which legal basis we will rely upon to do so. You can object to any new purposes at any time.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal third parties at the University of Warwick for the purposes of conducting research but only if you have explicitly consented to partake in the research.
  • External third party service providers acting as data processors based in the UK and USA who provide IT and system administration services. We have appropriate contractual and technical safeguards in place with all service providers to ensure compliance with data protection legislation.

6. INTERNATIONAL TRANSFERS

The external third party we use to provide the two-step verification for the Care Companion website are based outside the European Economic Area (EEA) so their processing of your telephone number only will involve a transfer of data outside the EEA. We ensure a similar degree of protection is afforded to it by ensuring specific contracts approved by the European Commission, which give personal data the same protection it has in Europe, are in place. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

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

7. DATA SECURITY

We work hard to have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In particular:

  • We encrypt your password and all communications between your computer and the Care Companion;
  • We test all the code to ensure no information is lost, as well as recovery processes and backups on a regular basis;
  • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to the site;
  • We offer you two-step verification when accessing Care Companion for the first time and/or when accessing Care Companion from a new device;
  • We restrict access to your personal data to those employees, agents, contractors and other third parties who need to access that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations;
  • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. 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 requirements.

Details of retention periods for your personal data are set out below:

  • Your personal data will retained for as long as your account is active with Care Companion.
  • Once a request to close or delete an account has been received, your personal data will be kept for period of 6 months from that request date before it is permanently deleted. This time period has been determined in line with Care Companion’s back-up systems.
  • As per the Terms of Care Companion, we will contact you, via email, after 6 months of inactivity to see whether you still want to continue with your Care Companion account. If we do not receive a response from you or there is no activity on your Care Companion account following our communications, we will close your account after a further 6 months.

Please also note the following in relation to retention of your personal data:

  • Your telephone number will be held by our data processor who is the service provider of the two-step verification functionality.
  • If you agree to participate in research then the retention of any data collected in association with that research will have its own retention period which will be communicated to you at the time your consent is obtained to participate.
  • In some circumstances you can ask us to delete your data: please see your legal rights section below for further information.
  • In some circumstances we may 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.

9. YOUR LEGAL RIGHTS

Under Data Protection Legislation, you have rights as an individual which you can exercise in relation to the information we hold about you. These rights include:

  • Request access to your personal data;
  • Request correction of your personal data;
  • Request erasure of your personal data;
  • Object to processing of your personal data;
  • Request restriction of processing your personal data;
  • Request transfer of your personal data; and
  • Right to withdraw consent.

Please visit the Information Commissioner’s Office webpages and the University of Warwick’s Data Protection webpages for further information on your rights.

If you wish to exercise any of the rights set out above, please contact our DPO.

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