ras mattis consectetur purus sit amet fermentum. Cras justo odio, dapibus ac facilisis in, egestas eget quam. Morbi leo risus, porta ac consectetur ac, vestibulum at eros. Praesent commodo cursus magna, vel scelerisque nisl consectetur et. Vivamus sagittis lacus vel augue laoreet rutrum faucibus dolor auctor. Aenean lacinia bibendum nulla sed consectetur. Praesent commodo cursus magna, vel scelerisque nisl consectetur et. Donec sed odio dui. Donec ullamcorper nulla non metus auctor fringilla. Cras mattis consectetur purus sit amet fermentum. Cras justo odio, dapibus ac facilisis in, egestas eget quam. Morbi leo risus, porta ac consectetur ac, vestibulum at eros. Praesent commodo cursus magna, vel scelerisque nisl consectetur et. Vivamus sagittis lacus vel augue laoreet rutrum faucibus dolor auctor. Aenean lacinia bibendum nulla sed consectetur. Praesent commodo cursus magna, vel scelerisque nisl consectetur et. Donec sed odio dui. Donec ullamcorper nulla non metus auctor fringilla. Cras mattis consectetur purus sit amet fermentum. Cras justo odio, dapibus ac facilisis in, egestas eget quam. Morbi leo risus, porta ac consectetur ac, vestibulum at eros. Praesent commodo cursus magna, vel scelerisque nisl consectetur et. Vivamus sagittis lacus vel augue laoreet rutrum faucibus dolor auctor. Aenean lacinia bibendum nulla sed consectetur. Praesent commodo cursus magna, vel scelerisque nisl consectetur et. Donec sed odio dui. Donec ullamcorper nulla non metus auctor fringilla. Cras mattis consectetur purus sit amet fermentum. Cras justo odio, dapibus ac facilisis in, egestas eget quam. Morbi leo risus, porta ac consectetur ac, vestibulum at eros. Praesent commodo cursus magna, vel scelerisque nisl consectetur et. Vivamus sagittis lacus vel augue laoreet rutrum faucibus dolor auctor. 

Who we are and what these terms and conditions do

These terms and conditions ("Terms") describe the basis upon which you may use the Goldster platform  ("Goldster Platform"). The Goldster Platform is made available to you for use on our website www.goldster.co.uk. Your use of our website when accessing the Goldster Platform is subject to our Website Terms and Conditions.

Goldster is operated and provided to you by:

• Goldster, which is a trading name of Goldster Limited, a private limited company registered in England under company number 13084427 and having its registered office at Stag House, Old London Road, Hertford, England, SG13 7LA ("Goldster"); and
• Care Visions Healthy Ageing ), which is a trading name of Care Visions Healthy Ageing Limited, a private limited company registered in England under company number 13079005 and having its registered office at Stag House, Old London Road, Hertford, England, SG13 7LA ("Care Visions").

Goldster and Care Visions will be referred to as "we", "us", "our" in these Terms.

We specialises in the delivery of therapeutic and non-pharmacological intervention services for older people.. Our services consist of programs designed to provide non-pharmacological interventions in the form of therapies and activities for various stages and symptoms of ageing. Interventions offered as part of the programs typically include, but are not limited to, cognitive stimulation, reminiscence therapy, physical exercise, reality orientation, music therapy, art therapy, multisensory stimulation, massage, aromatherapy, validation therapy, , meditation and gardening therapy. These services are provided both in person (on a one-to-one basis at a service user's home, or in a group setting), and remotely through video link and pre-recorded video content. We may add to or cease providing any of these services at any point.

Licence to use the Goldster Platform

Subject to these Terms, we license you to use the Goldster Platform and any updates or supplements to it. You will be entitled to make use of the services made available through the Goldster Platform ("Services"). These Services may consist of, but are not limited to:

• live classes;
• pre-recorded instructional videos;
• future research opportunities; and
• Educational lectures.

Your privacy

We only use any personal data we collect through your use of the Goldster Platform in the ways set out in our Privacy Policy.  

Please be aware that internet transmissions are never completely private or secure and that  any message or information you send using the Goldster Platform may be read or intercepted by others, even if there is a special notice that a particular transmission is encrypted.

Support for the Goldster Platform and how to tell us about problems

• Contacting us (including with complaints). If you think the Goldster Platform or the Services are faulty or misdescribed or wish to contact us for any other reason please email our customer service team at team@goldster.co.uk
• How we will communicate with you. If we have to contact you we will do so by email and/or SMS using the contact details you have provided to us.

How you may use the Goldster Platform

In return for your agreeing to comply with these Terms you may access, view and use the Goldster Platform and any Services on our website through your internet browser. This may be done on a desktop, handheld or other mobile device capable of accessing the internet, and which meets the minimum technical requirements to utilise our Goldster Platform. You may only use the Goldster Platform and Services for your personal purposes.

You must be 18 to accept these terms and use the Goldster Platform

You must be 18 or over to accept these terms and use the Goldster Platform. 

You may not transfer the Goldster Platform to someone else

We are giving you personally the right to use the Goldster Platform. This includes your use of the Goldster Platform for the benefit of someone to whom you provide care, or for whom you are responsible (e.g. where you have been granted a power of attorney by someone). You may not transfer the use of the Goldster Platform to someone else, whether for money, for anything else or for free.

You must keep your account details safe

We will collect information from you in order to register you (or the individual who you are responsible for or providing care to) for the Goldster Platform. This may involve the creation of an account which is personal to you (or the individual you are responsible for). Such an account may involve issuing you with a unique identification reference, or the creation of a unique login and/or password.

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.

We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms of use.

If you know or suspect that anyone other than you knows your user identification code or password, you must immediately notify us at team@goldster.co.uk

Changes to these terms

We may need to change these Terms to reflect changes to our services, our users' needs and our business priorities or as may be required by law or best practice.

We will give you notice of any change by notifying you of a change when you next start the App.

If you do not accept the notified changes, depending on the nature of the change you may be permitted to continue to use the App in accordance with the existing terms but certain new features may not be available to you or at our sole discretion we may notify you that you will not be permitted to continue to use the Goldster Platform.

Update to the Goldster Platform

From time to time we may automatically update the Goldster Platform to upload, update or remove content or materials available on the Goldster Platform, to update or amend the Services available through the Goldster Platform, improve performance, enhance functionality or address security issues.

If someone else owns the phone or device you are using

If you access, view or use the Goldster Platform on any device not owned by you, you must have the owner's permission to do so. You will be responsible for complying with these terms, whether or not you own the device.

We may collect technical data about your device

By using the Goldster Platform, you agree to us collecting and using technical information about the devices you use the Goldster Platform on and related software, hardware and peripherals to improve our products and to provide any services to you. We may collect this information by using cookies and other similar technologies. Please see our Cookie Policy or further details on our use of cookies.

We are not responsible for other websites you link to

The Goldster Platform may contain links to other independent websites which are not provided by us. Such independent sites are not under our control, and we are not responsible for and have not checked and approved their content or their privacy policies (if any).

You will need to make your own independent judgement about whether to use any such independent sites, including whether to buy any products or services offered by them.

Your contract with us

The prerequisite for the use of the Goldster Platform (including any service packages subject to cost and/or free trial offers or other services) is that you (or the person for whom you are responsible) register your details with us. We can offer free trials of content and/or Services on the Goldster Platform during a trial period either in the form of independent offers or upon free registration, or in combination with the purchase of a paid service package. Irrespective of any agreements or terms and conditions providing otherwise, there is no entitlement to a free trial.

When we confirm your registration with us (for example, where you complete the creation of a user account for use of the Goldster Platform) you will have entered into a contract with us for the provision of services. You will also be deemed to have entered into a contract with us where we accept payment from you in exchange for the provision of services to you (e.g. a paid Services package) or where we activate an unpaid service, feature, trial or other offer for you.

Payment

You understand and agree that any sums charge by us to you will include value added tax at the prevailing rate when such charge is made. We will send you invoices for payments made by you electronically to the email address provided by you when you registered with us (or any subsequent email address provided by you to us which we acknowledged).

If payment in one complete sum for a certain period has been agreed, the total sum shall be due at the beginning of that period, unless agreed otherwise. For the rest, the agreed fees shall be due immediately, unless agreed otherwise.

If we have agreed to charge you monthly for a particular Service, then the agreed monthly amounts shall be debited from the bank account, debit / credit card, or other payment method that was used by you when we accepted payment from you.  Where you agree to pay by direct debit, you (or the person for whom you are responsible) authorise us to collect payments owed by you from the account nominated at the time when you provide us with your direct debit instruction / authorisation.

If you (or the person for whom you are responsible) fail to pay us when payment is due, we will have the right to block your access to the Goldster Platform temporarily until the owed payment is received, after giving prior warning and without prejudice to any rights you may have under law. In this case, the term of the contract entered into between us shall remain unaffected by the temporary block.

We reserve the right to withold or suspend your access to the Goldster Platform in the event of any delay or failure to pay any sums due to us under these Terms. 

Expiry or termination of our contract with you

The term of the contract between us for the operation of your account will be for the duration of the account, and will end either when you close the account, or where we close or terminate the account (whichever is earlier).

The term of the contract between us for a paid service that you have purchased will be the agreed period of the service being provided to you. Following the expiry of the agreed period, the contract between us will automatically renew for subsequent term that is equal to the initially agreed period. You have the right to cancel the services being provided by terminating your contract with us at least one month prior to the expiry of the term (or renewed term).

Notwithstanding the above, where you have availed of an unpaid trial of our services, we or you may terminate the contract any time prior to the expiry of the trial period, in which case any paid service packaged purchased by you in conjunction with the unpaid trail will also terminate (i.e. the paid for service package due to commence at the expiry of the unpaid trial will not commence). HOWEVER, WHERE YOU DO NOT TERMINATE THE CONTRACT PRIOR TO THE EXPIRY OF THE TRIAL PERIOD, ANY PAID SERVICE THAT YOU HAVE PURCHASED IN CONJUNCTION WITH THE UNPAID TRIAL SHALL BE DEEMED TO HAVE COMMENCED ON THE DAY FOLLOWING THE EXPIRY OF THE TRIAL PERIOD, AND THE TERM AND TERMINATION OF SUCH CONTRACT (FOR THE PAID SERVICE) WILL BE SUBJECT TO THE PARAGRAPH ABOVE.

You can terminate a contract with us online by using the relevant feature for this purpose on your account, or by contacting us on the details below:

team@goldster.co.uk

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Licence restrictions

You agree that you will:

• not rent, lease, sub-license, loan, provide, or otherwise make available, the Goldster Platform or the Services in any form, in whole or in part to any person without prior written consent from us;
• not copy the Goldster Platform or the Services (including, without limitation, any images and/or live or pre-recorded audio or video content provided on the Goldster Platform), except as part of the normal use of the Goldster Platform or where it is necessary for the purpose of back-up or operational security;
• not translate, merge, adapt, vary, alter or modify, the whole or any part of the Goldster Platform, or Services nor permit the Goldster Platform or the Services or any part of them to be combined with, or become incorporated in, any other programs, except as necessary to use the Goldster Platform and the Services on devices as permitted in these Terms;
• not disassemble, de-compile, reverse engineer or create derivative works based on the whole or any part of the Goldster Platform or the Services nor attempt to do any such things, except to the extent that (by virtue of sections 50B and 296A of the Copyright, Designs and Patents Act 1988) such actions cannot be prohibited because they are necessary to decompile the Goldster Platform to obtain the information necessary to create an independent program that can be operated with the Goldster Platform or with another program (Permitted Objective), and provided that the information obtained by you during such activities:
• is not disclosed or communicated without our prior written consent to any third party to whom it is not necessary to disclose or communicate it in order to achieve the Permitted Objective; and
• is not used to create any software or services that are substantially similar in their expression to the Goldster Platform or the Services;
• is kept secure; and
• is used only for the Permitted Objective;
• comply with all applicable technology control or export laws and regulations that apply to the technology used or supported by the Goldster Platform or any Service.

Acceptable use restrictions

You must:

• not use the Goldster Platform in any unlawful manner, for any unlawful purpose, or in any manner inconsistent with these Terms, or act fraudulently or maliciously, for example, by hacking into or inserting malicious code, such as viruses, or harmful data, into the Goldster Platform, or any operating system;
• not infringe our intellectual property rights or those of any third party in relation to your use of the Goldster Platform or any Service, including by the submission of any material (to the extent that such use is not licensed by these Terms);
• not transmit any material that is defamatory, offensive or otherwise objectionable in relation to your use of the Goldster Platform or any Service;
• not use the Goldster Platform or any Services in a way that could damage, disable, overburden, impair or compromise our systems or security or interfere with other users; and
• not collect, record or harvest any information or data from any Service or our systems or attempt to decipher any transmissions to or from the servers running any Service.

Intellectual property rights

All intellectual property rights in the Goldster Platform and the Services throughout the world belong to us (or our licensors) and the rights in the Goldster Platform and Services are licensed (not sold) to you. You have no intellectual property rights in, or to, the Goldster Platform or the Services other than the right to use them in accordance with these Terms.

Our responsibility for loss or damage suffered by you

You agree and acknowledge that your use of the Goldster Platform, including the information or Services provided through it, is at your own risk, To the fullest extent permitted by law, we expressly exclude:

• any representations, conditions, warranties, guarantees, or other terms (whether express or implied) which may be applicable under law; and
• any and all liability (including, without limitation, under delict, tort, breach of contract or any other rule of law) for any direct, indirect, special or consequential loss or damage incurred by you (or anyone for whom you are responsible);

which may arise as a result of your use (or the use by someone for whom you are responsible) of the Goldster Platform, or any information, Services or other content and materials available on the Goldster Platform.

Subject to the above, we are responsible to you only for foreseeable loss and damage caused by us, provided the loss or damage has not arisen due to you (or the person for whom you are responsible) breaching these Terms. If we fail to comply with these Terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breaking these Terms or our failing to use reasonable care and skill, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time you accepted these Terms, both we and you knew it might happen.

We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors or for fraud or fraudulent misrepresentation.

If defective digital content that we have supplied damages a device or digital content belonging to you, we will either repair the damage or pay you compensation. However, we will not be liable for damage that you could have avoided by following our advice to apply an update offered to you free of charge or for damage that was caused by you failing to correctly follow installation instructions or to have in place the minimum system requirements advised by us.

We are not liable for business losses. The Goldster Platform and Services are for domestic and private use. If you use the Goldster Platform or Services for any commercial, business or resale purpose we will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

Safety warning and disclaimer

• Unless expressly stated or agreed otherwise by us at the time we provide you with use of the Goldster Platform, or use of the Services on the Goldster Platform, the information and Services available on the Goldster Platform are intended for informational, educational and interest use only. The information and Services provided on the Goldster Platform have not been prepared for any individual's specific requirements, and each individual (or those that are responsible for them) must ensure that the information is appropriate for them.
• You should consult your doctor or general practitioner before taking any action based on the information or Services provided on the Goldster Platform. You should not rely on the information and services provided by us as a substitute for, nor does it replace, professional medical advice, diagnosis, or treatment. If you have any questions or concerns about your health, you should always consult with your doctor, general practitioner or other appropriately qualified health care professional. Do not disregard, avoid or delay obtaining medical advice on the basis of any information or services available from us (whether provided in person or remotely, including on this Goldster Platform), or which may be provided by us on any third party website. You should be aware that professionals in the medical or health care field may have different opinions. Due to this and also because of regular advances in medical research and knowledge we strongly recommend that you independently verify any information, advice, materials Services, or other content available on the Goldster Platform before using or relying on them.
• You acknowledge and accept that the use by you of any information or Services provided by us on our Goldster Platform:
  • does not constitute (and must not be taken to be) medical or therapeutic advice;
  • does not constitute a doctor-patient, or health care professional-client relationship, between us (or any platform or third party service on which our information or services are being viewed/received) and you;
  • is on the basis that you are medically (both physically and mentally) fit for, and do not have any medical conditions, illnesses or other impediments that would prevent you from, using the information and Services on the Goldster Platform (for example, you are physically and mentally fit enough to participate in a live yoga class broadcasted through the Goldster Platform);
  • is on the basis that prior to performing any activities or exercises shown in any content, materials, information or Services on the Goldster Platform, you have ensured that you are in a safe environment which is free from any hazards or dangers that would prevent you from performing the activity or exercise, or which may cause you harm, injury or damage when doing so (e.g. there are no slip or trip hazards near you); and
  • is solely at your own risk.

Although we make reasonable efforts to update the information and Services provided by the Goldster Platform, we make no representations, warranties or guarantees, whether express or implied, that such information is accurate, complete or up to date.

While every effort is taken to ensure the content, materials, information and Services provided on the Goldster Platform are accurate, we and our group companies and affiliates, and their directors, employees, contracted companies, contractors, expert panel members, peer reviewers, presenters, guest speakers and third-party suppliers are not responsible for, and shall have no liability for, the scientific accuracy or validity of any written, audio, video or live content, advice, information, Services or other materials provided.

Please also be aware that whilst we have engaged presenters, experts and other individuals to present or provide information, Services, content and materials on the Goldster Platform, their views and opinions are entirely their own, and may not reflect the views, opinions and values of Goldster or Care Visions.

Please back-up content and data used with the Goldster Platform. We recommend that you back up any content and data used in connection with the Goldster Platform, to protect yourself in case of problems with the Goldster Platform or the Services.

Check that the Goldster Platform and the Services are suitable for you. The Goldster Platform has not been developed to meet your individual requirements. Please check that the facilities and functions of the Goldster Platform meet your requirements.

We are not responsible for events outside our control. We are not responsible or liable if our provision of the Goldster Platform or the Services is affected or delayed by an event outside our control.

We may end your rights to use the Goldster Platform if you break these Terms

We may end your rights to use the Goldster Platform and/or the Services at any time by contacting you if you have breached these Terms. If what you have done can be put right we will give you a reasonable opportunity to do so.

If we end your rights to use the Goldster Platform and/or the Services:

• you must stop all activities authorised by these Terms, including your use of the Goldster Platform and the Services;
• you must delete or remove the Goldster Platform from all devices in your possession and immediately destroy all copies of the Goldster Platform which you have and confirm to us that you have done this;
• we may remotely access your devices and remove the Goldster Platform from them and cease providing you with access to the Services.

We may transfer this agreement to someone else

We may transfer our rights and obligations under these Terms to another organisation. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under the contract.

You need our consent to transfer your rights to someone else

You may only transfer your rights or your obligations under these Terms to another person if we agree in writing.

No rights for third parties

This agreement does not give rise to any rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of this agreement.

If a court finds part of this contract illegal, the rest will continue in force

Each of the paragraphs of these Terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.

Even if we delay in enforcing this contract, we can still enforce it later

Even if we delay in enforcing this contract, we can still enforce it later. If we do not insist immediately that you do anything you are required to do under these Terms, or if we delay in taking steps against you in respect of your breaking this contract, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.

Which laws apply to this contract and where you may bring legal proceedings

These Terms, their subject matter and their formation, are governed by the law of England and Wales.  You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Scotland, you may also bring proceedings in Scotland, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland and if you are resident of England and Wales, you may also bring proceedings in England and Wales.

This Goldster Platform is intended for use primarily in the United Kingdom. However, the Goldster Platform is also available in other countries around the world, and where you access the Goldster Platform from a country outside the United Kingdom, your use of the Goldster Platform may be subject to the laws of that country.

Last updated: 3 March 2021

1. Introduction

Welcome to our Privacy Policy.

Goldster Limited is a private limited company (Company No. SC367451) incorporated in England. Our  registered address is Stag House, Old London Road, Hertford, England, SG13 7LA Company Number 13079005 (hereafter referred to as 'the Client'). n this Privacy Policy, we refer to ourselves as "Goldster", "us", "our" or "we".

Goldster is the data controller in relation to your personal data.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you how and why we collect your personal data, how we look after your personal data, and about your privacy rights and how the law protects you.

This Privacy Policy explains how we collect and process your personal data when you:

1. visit our website or use our apps;
2. contact us directly;
3. use or subscribe to any of our services or products;
4. participate in our research or feedback projects;
5. collaborate with us (e.g. where you peer review our publications); and
6. sign up to receive updates and newsletters from us.

This website, and the services we offer, are not intended for children. We do not knowingly collect data about children. If you become aware that we may have been given data about a child, please contact us as soon as possible.

It is important that you read this Privacy Policy together with any other privacy policy or privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

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:

1. Identity Data: your name, title, address, telephone/mobile number, email address, name of organisation, date of birth, gender, marital status, next of kin / emergency contact;
2. Financial Data: bank account and payment card details;
3. Transaction Data: details and records about payments to and from you, including details of products and services that you have purchased from us;
4. Health Data: disabilities, current illnesses/conditions (e.g. dementia, including current stage and cognitive, neuropsychiatric and functional symptoms), current medications (and dosages), race/ethnicity and sexual orientation;
5. GP Details: the name, address, email and phone number of your GP/doctor;
6. Personal Descriptors: mood, lifestyle information, quality of life and personal preferences;
7. Images and Video Data: photographs and video footage;
8. Technical Data: 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 this website;
9. Profile Data: this includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
10. Usage Data: information about how you use our website, apps, products and services; and
11. Marketing and Communications Data: your preferences in receiving marketing from us and our third party partners, and your communication preferences. This may include where we recommend third party services (e.g. online clubs and groups) which we believe you may be interested in.

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 website 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

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

• Direct interactions: You may give us your Identity Data, Financial Data, Medical Data, and Marketing and Communication Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• participate in our research or feedback projects;
• collaborate with us (e.g. where you peer review our publications and research);
• subscribe to our services or publications;
• request marketing to be sent to you; or
• give us general feedback or contact us.
• Those responsible for you: We may be given your Identity Data, Financial Data, Medical Data, and Marketing and Communication Data by someone who has responsibility for your care or affairs (e.g. a caregiver or someone to whom you have given a power of attorney). In this case, we will also collect and process the personal data of the individual who has responsibility for you.
• Third parties or publically available sources: We may obtain your Identity Data from third parties that have referred you to us or publically available sources as set out below:
• when you are referred to us by someone who is responsible for your care, or who has authority to act on your behalf (e.g. a carer, or someone to whom you have granted power of attorney);
• where you are referred to us by another community organisation or service provider;
• where you are referred to us by a GP/doctor or other health professional; and
• where we have obtained your information from publically available sources, such as your online profile/bio (e.g. where we have located you via the internet in order to contact you about peer reviewing our publications and research).
• Automated technologies and interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy or further details.

Care Visions may supplement the information that you provide to us, or which we are given, with information that we receive or obtain from other sources, such as from our professional advisors, partners, and agents of Care Visions, third parties with whom we interact, and publically available sources.

4. Purposes for which we use your personal data

We have set out below, in table format, a description of all the ways we plan to use your personal data and which 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 us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We may use your Identity Data, Technical Data, Usage Data and Marketing and Communication Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which updates, products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us, or subscribed to or purchased products or services from us and you have not opted-out of receiving that marketing. Alternatively, you may receive marketing communications where you have specifically opted-in to receive these (for example, by signing up for updates or newsletters on our website, or by signing up whilst using our apps).

You can ask us to stop sending you marketing at any time by clicking "unsubscribe" on any email marketing sent to you, by changing your preferences in our apps, or alternatively by contacting our Data Protection Manager on the details below.

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

Cookies

This website uses cookies to improve your experience while you navigate through the website. Out of these cookies, the cookies that are categorised as "necessary" are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyse and understand how you use this website. These cookies will be stored in your browser only with your consent.

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 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 Cookie Policy.

Change of purpose

We will only process your personal data for the purposes for which we collect 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.

5. Disclosure and transfer of your personal data

We may share your personal data with the third parties set out below for the purposes set out in the table at section 4 (Purposes for which we use your personal data) above:

• where you are a service user or person with responsibility for a service user, we may share your personal data with therapeutic and health care professionals/practitioners that are providing products and services to you, or to someone for whom you are responsible. This is so they can provide the products or services requested, communicate with you for this purpose, and provide you with feedback and updates on the provision of the products and services (e.g. how much progress a service user has made with the chosen treatment option, and what further actions require to be taken);
• where you are a service user for whom someone else is exercising responsibility (e.g. where you have a caregiver, or a duly appointed attorney who acts on your behalf), we will disclose your information to the person exercising responsibility for you;
• vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management vendors and other cloud-based solutions providers that are used but us in the conducting our business. We contract with such vendors to ensure that they only process your personal data under our instructions and ensure the security and confidentiality of your personal data by implementing the appropriate technical and organisational measures for such processing;
• where you (or someone for whom you have responsibility) participate in our research or feedback projects, we may disclose your personal data to our trusted third party research partners who we have engaged to conduct the research / feedback project on our behalf;
• our professional advisors (e.g. lawyers, accountants, etc);
• third parties to whom we are required to transfer personal data by law, such as law enforcement bodies, governmental and regulatory bodies, the courts and other competent authorities that may request personal data in connection with any inquiry, court order, or other legal or regulatory procedures which we would need to comply with; we may also share personal data to establish or protect our legal rights, property or safety, or the rights, property or safety of others, or to defend against legal claims; and
• any third party connected with business transfers; we may transfer your personal data to third parties, in connection with a reorganisation, restructuring, merger, acquisition, or transfer of our business or assets, provided that the receiving party agrees to treat your personal data in a manner consistent with data protection law.

6. International transfers

We may transfer your personal data to controllers or processors located outside of the United Kingdom and/or the European Economic Area (EEA). This is primarily to allow us to receive IT services (e.g. cloud storage services, email/webmail services and customer relationship management services) from vendors located in non-UK or non-EEA jurisdictions. However, we will only transfer your personal data to a vendor in a non-UK or non-EEA country where:

1. such countries have been deemed to provide an adequate level of protection for personal data by the relevant authorities in the UK or the European Commission;
2. where we have in place a valid data transfer agreement with the data recipient (such as the European Commission standard contractual clauses, or any equivalent clauses approved by the authorities in the UK); or
3. where we are otherwise permitted to make the transfer under data protection law.

Please contact us 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 have put 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 addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

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 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.

When we no longer need to use your personal data, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to).

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

9. Your legal rights

Under data protection law, you have certain rights in relation to your personal data:

1. 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.
2. Request correction of the personal data that we hold about you. 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.
3. 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 applicable law. Please 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.
4. Object to 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.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data's accuracy;
• where our use of the data is unlawful but you don’t want us to erase it;
• 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
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

6. Request the transfer of your personal data to you or to a third party. 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.
7. Withdraw consent at any time 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.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or access someone else's personal data on their behalf (or to exercise any of the other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Third-party links

This website and our apps may include 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 statements. When you leave our website or apps, we encourage you to read the privacy policy of every website you visit.

11. Contact us

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions in relation to this Privacy Policy, including any requests to exercise your legal rights (or someone else's legal rights on their behalf), please contact the Data Privacy Manager using the details below.

Data Privacy Manager

Care Visions Healthy Ageing

Email: dataprivacy@carevisions.co.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 us in the first instance.

12. Keeping your information up to date

To help Care Visions keep accurate information, you must tell the Data Privacy Manager about changes to information or personal details relating to you, or to someone for whom you are exercising responsibility, in particular, any changes to contact or financial details. If you know that Care Visions holds any personal details about you, or someone for whom you exercise responsibility, that are out of date or inaccurate, you must tell Care Visions as soon as possible.

13. Notification of changes

Care Visions may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. However, the last update date is given at the start of this Privacy Policy, and we encourage you to review this Privacy Policy periodically so you remain informed of how we use your personal data.