Privacy Policy

1. Introduction and important information

Where4Care LTD (“We” or “us”) are committed to protecting and respecting your personal data and privacy. 

This privacy policy relates to how we use and collect personal data:

• collected from you when you use or purchase our services as a Consumer User or Authorised User of a Provider;
• collected from you or your device when you access our website or Platform; and 
• collected from you or a person with authority to acting on your behalf when setting up and administrating a Where4Care profile and matching with Providers. 

It also relates to our use of any personal information you provide to us by telephone (including SMS), in written correspondence (including letter and email) and in person. 

Please note that: 

• our services and our website are not intended for children under the age of 18 and we do not collect data relating to children; and 
• our website and services 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, we encourage you to read the privacy policy of every website you visit.

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including but not limited to the Data Protection Act 2018 and the General Data Protection Regulation 2016 (GDPR), described in this policy as the “Data Protection Laws”.

This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page, so please check back regularly. 

2. WHO WE ARE AND How to contact us

1. For the purpose of the Data Protection Laws, we will be the data controller of Consumer data and a Data Processor for data supplied by a Provider or its Authorised Users. Where we act as a processor, we will process personal data in accordance with the Data Processing Addendum available here.  
2. We are a private limited company registered in England and Wales under company number 15136790. Our registered office is at James House, Newport Road, Albrighton, WV73FA. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:
3. FAO: Admin Team

James House
Newport Road
Albrighton
Wolverhampton
WV73FA
United Kingdom
Email: info@blossombridge.co.uk

Telephone: 03300437015 and ask to speak to the Privacy Officer.  

4. 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.

3. The data we collect about you

1. We collect and process personal data. Typically the personal data we collect and process will include identity, contract, transactional, technical, profile, usage and marketing and communications data such as:
   1. Identity Data includes first name, last name, title or other identifier (such as job title), marital status, date of birth, gender and images. 
   2. Contact Data includes billing address, email addresses and telephone numbers.
   3. Consumer Profile Data includes username and password, gender, care requirements and preferences, location, medical requirements (special category data – see below), language requirements, feedback and survey responses. We will not collect and share identifying data such as name or NHS number of the person requiring care;
   4. Provider Profile Data includes Authorised User names and contact details, bed availability, service availability, Platform usage, business details and regulatory rankings. 
   5. Usage Data includes information about how you use our website, products and services.
   6. Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
   7. Technical Data 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 this website.

Please note that we may collect and/or process other personal data from time to time. 

1. 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 to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your 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 solely in accordance with this policy.
2. We may collect Special Categories of Personal Data about you or the person requiring care (specifically information about health). We collect this information in order to make suitable person to Provider matches and so with your consent or the person requiring care’s consent. We will not collect any information about criminal convictions and offences.
3. We only collect data from you directly or via third parties (see the section Third Parties below). 

4. How is your personal data collected?

1. We use different methods to collect data from and about you including through:
   1. Direct interactions. You may give us your personal data by setting up a Where4Care profile and/or Account, filling in forms or by corresponding with us by post, phone, messaging service, email or otherwise. 
   2. Automated technologies or interactions. As you interact with our Platform and 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. We will also use your Profile data to suggest matches suitable to your criteria.  Please see our cookie policy for further details.
   3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
      1. Technical Data from the following parties:
         • analytics providers; and 
         • search information providers.
      2. Identity and Contact Data from publicly available sources such as Companies House (Provider’s only).

5. 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 all or part of a service you have with us but we will notify you if this is the case at the time.

6. How your data will be used

1. We use information held about you to:
   1. carry out our obligations arising from any contracts entered into between you and us and provide our services, including any third-party services we make available to you; 
   2. carry out feedback and research on our services; and
   3. notify you about changes to our services.
2. We never sell your personal data to third parties or allow third parties to contact you without your permission. 
3. We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below (please also see clause 7 below). We may process your personal data without your knowledge or consent where this is required or permitted by law.
4. 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. 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 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new Consumer User or Authorised User.	Identity Contact	Performance of a contract with you
To provide Consumers with free services including but not limited to: Giving the Consumer an indicator of care costs through our care estimator; Locating Provider Availability based on the criteria specified by the Consumer; and Connecting Consumer Users with Providers so that they may communicate through Where4Care in-built messaging regarding care service.	Identity Contact Consumer Profile Data Provider Profile Data	Performance of a contract with you Explicit Consent (where Health data is provided).
To provide Providers with Services to you including: Matching Provider Availability with care need criteria specified by the Consumer. Connecting Providers with Consumers so that they may communicate through Where4Care in-built messaging regarding care services.	Identity Contact Usage Consumer Profile Data Provider Profile Data Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) Explicit Consent (where Health data is provided).
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract 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 our products/services)
To enable you to partake in a competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage Profile	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

7. lawful basis for processing

1. We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:
   1. Contractual obligation – means processing that is necessary to comply with our obligations arising out of a contract, for example, where you have bought services from us we will use the personal data you provide to fulfil our contractual obligations . 
   2. Legitimate Interest – means in 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 you personal data for our legitimate interests. Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest services or obtaining your feedback on our service.  
   3. Consent – We will seek to obtain your consent to process:
      1. your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above); and
      2. any special category data. 
   4. Legal obligation – We may process your data where we it is necessary for us to do so to comply with the law. 

8. THIRD PARTIES and sharing information

1. We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you.  We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
2. Please see below the list which sets out the categories of recipients of personal data.

SERVICE PROVIDERS WHO MAY RECEIVE YOUR PERSONAL DATA

Local Authorities and Care Regulators

Google and other analytics providers

Google Maps (for location services)

IT Support Services

Email Provider

Website Provider

Banks

Online payment providers

Accountants

Insurers

Solicitors

Software Providers

Feedback aggregators and collectors

Marketing Agencies

Website Hosting Provider