Website Privacy Policy
1 Introduction
1.1 Important information and who we are
Mobilise Care Ltd
Company Number 11896322, International House, 64 Nile Street, N1 7SR, London, United Kingdom, N1 7SR
Welcome to Mobilise Care Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).
At Mobilise Care Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the DPA 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include:
Customers
Suppliers
Business contacts
Employees/Staff Members
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
1.2 Who is your Data Controller
Mobilise Care Ltd is your Data Controller and responsible for your Personal Data we are registered with the Information Commissioner's Office: ZB197029. Our Data Protection Officer is James Townsend. Any inquiries about your data should either be sent to us on email at data@mobiliseonline.co.uk or sent in a letter to International House, 64 Nile Street, N1 7SR, London, United Kingdom.
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.
1.3 Processing data on behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
2 Legal basis for data collection
2.1 Types of data / Privacy Policy scope
“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
Standard User Data: Profile data, marketing preferences and contact details
Special Category Data: Special categories of personal data including health data and data relating to your ethnicity.
We also collect, use and share Aggregated Data such as current priorities for carers and email open rates. 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. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
For the purposes of our business we also collect what is known under the GDPR as special categories of Personal Data. We collect the following types of special Personal Data: health data
In order to collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. We explain which justifications we rely on in paragraph 2.2 below.
2.2 The legal basis for collecting that data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
3
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
For the special categories of data that we collect, the enhanced legal justification we rely on is: (a) the data subject has given explicit consent to the processing of such Personal Data for
one or more specified purposes (“Explicit Consent”)
3 Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4 Your rights and how you are protected by us
4.1 How does Mobilise Care Ltd protect customers' personal data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Mobilise Care Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.2 How to request your data and the process for obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
5. Your data and third parties
5.1 Will we share your data with third parties?
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or service providers or suppliers or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions), and obtaining your consent where required or appropriate.
We may also share Personal Data with interested parties in the event that Mobilise Care Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If Mobilise Care Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
5.2 Third-party links
This Site 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 Site, we encourage you to read the privacy policy of every website you visit.
6 How long will we retain your data for?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
7 Age limit for our users
You must not use Mobilise Care Ltd unless you are aged 18 or older. If you are under 18 and you access Mobilise Care Ltd by lying about your age, you must immediately stop using Mobilise Care Ltd. This website is not intended for children and we do not knowingly collect data relating to children.
8 International transfer of data
Your information may be stored and processed outside of the United Kingdom and the European Economic Area, including in the US or other countries or jurisdictions where Mobilise Care Ltd has facilities, suppliers, or commercial partners that we use to provide our services. When transferring information outside of the UK and EEA, we ensure that appropriate and suitable safeguards and technical measures are in place to protect your personal data. To do this, we may make use of standard contractual clauses that have been approved by the European Commission and the UK authorities, or we implement other similar measures required by laws around the world.
9 Notification of changes and acceptance of policy
We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 6 January 2022. By using Mobilise Care Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Mobilise Care Ltd will constitute your express acceptance of any modifications to this Privacy Policy.
10 Interpretation
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Mobilise Care Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Mobilise Care Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Mobilise Care Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Mobilise Care Ltd legal department.