CareLoop Health Ltd (“CareLoop Health Ltd”, “we”, “us”, “our”) designs and develops applications (“Apps”) to empower users to manage their health and improve their health outcomes.
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal data”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are company number 13219481 registered in the United Kingdom. Our registered office is at CareLoop Health Ltd, Renold Building, 81 Sackville St, Manchester, M1 3NJ.
1. Data Protection Officer
We have appointed a data protection officer (DPO) who helps ensure we maintain our compliance with the Data Protection Act 2018 and the UK GDPR as it applies.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO at dpo@careloop.health.
2. Personal Data We Process
Personal data means any information about an individual from which that person can be identified.
As part of our relationship with you we will collect, use, store and transfer different kinds of personal data about you.
For app users, we may collect, use, store and transfer different kinds of personal data about you which we have collated these into groups as follows:
- Identity Data includes first name, last name, any previous names, username or similar identifier. As part of you being referred to us by your mental health team we will be provided with information (personal data) in relation to your identity (such as: name, date of birth, phone number) in order that we may contact you and so that your mental health team may identify you on our platform. As part of us delivering our service to you and supporting you, we will collect special category data (data set out in law as sensitive) in relation to your health and well-being from you directly. This will include data that you supply through the app questionnaires and through the CareLoop app, which can include details in relation to your health status, symptoms, well-being, quality of life, and functional abilities.
- Technical Data includes browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this app and website.
- Usage Data includes information about how you interact with and use our app, website, products and services.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific app or website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal 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;
- request information to be sent to you; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our services, 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
4. Our Lawful Bases for processing your data
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you explicitly sign up to our services.
5. How we use your personal data
We will only use your personal data for the purpose for which we collected it which includes the following:
- To register you as a new user which is necessary in the performance of a contract with you.
- To process and deliver our services which is necessary in the performance of a contract with you and for our legitimate interest.
- To manage your relationship with us which is necessary in the performance of a contract with you, to comply with a legal obligation and for our legitimate interest (for example, to keep our records updated and to study how users use our products/services).
- To improve our website, products/services, which is necessary for our legitimate interest (for example, to study how users use our products/services, to develop them, to improve our services).
- To recommend products or services which may be of interest to you which are necessary for our legitimate interest (to develop our products / services and grow our business).
If we need to use your personal data for an unrelated purpose to which it was collected, 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 this privacy policy and the data protection legislation, where this is required or permitted by law.
6. Sharing with other organisations
You expressly agree and consent that CareLoop may share your directly identifiable health data collected from you in our app with your care or clinical Team, we will not share your identifiable health data with any third parties outside of this.
In certain circumstances, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
We do not anticipate these circumstances to arise often and any disclosure made by us will always be in accordance with the requirements of data protection law.
Third-party links
This app and website 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 app or website, we encourage you to read the privacy policy of every website you visit.
7. Your Rights
Under data protection law, you have the following rights to your information:
- Your right of access - You have the right to ask us for copies of your personal information.
- Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - You have the right to ask us to erase your personal information.
- Your right to the restriction of processing - You have the right to ask us to restrict the processing of your personal information.
- Your right to object to processing - You have the right to object to the processing of your personal information.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
- Your right to withdraw consent - You have the right to withdraw consent provided to us for processing of your personal data.
In order to take up any of the rights you may contact us at: dpo@careloop.health
Please be aware if you were referred to use CareLoop by a mental health team we may need to contact the team that referred you to us in relation to this.
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 to exercise any of your 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.
8. Encryption of Data Sent Between Us
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.
We use Secure Sockets Layer (SSL) for secure data transfer between the app and our servers. This means that data is encrypted in transit.
CareLoop Health maintains appropriate organisational and technical measures to protect confidential health information. Where CareLoop provides services to NHS organisations, we support compliance with applicable NHS information governance requirements, including the Data Security and Protection Toolkit (DSPT).
9. How You Can Complain
If you have any complaints or are unhappy about the use of your data, then you should tell us by contacting dpo@careloop.health
You have a right, at any time, to lodge a complaint in the UK with the Information Commissioner's Office (ICO). This can be done at ico.org.uk/make-a-complaint. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
10. Retention Period for Personal Data
We will not hold onto your personal data for longer than is necessary for the purpose for which it was collected including for the purposes of satisfying any legal, accounting, reporting, or support requirements.
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.
By law we have to keep basic information about our users (including contact, identity and financial information and transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data. You can exercise this right at any time by contacting the DPO (see above).
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.
We will take all reasonable steps to destroy or erase from our system, all data which is no longer required.
11. Analytics
We use analytics tools to understand how our users interact with our software and to improve its performance. These tools may collect information such as the details of the pages within the app you have visited and how long you have spent viewing or interacting with the app content.
Analytics cookies are used only with your consent, which you can manage via our cookie settings. For more information about the cookies we use, please see our Cookies Policy.
12. Review of This Privacy Notice
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted on our website. You may like to print a copy for your records.
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 your relationship with us, for example a new address or email address.
If you have any question regarding our privacy policy, please contact us at dpo@careloop.health