Our Privacy Policy

• Accessing the Chime Care Domiciliary Platform (the 'CCD' Platform)

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided below and it is important that you read that information and, if you wish to use our services and access our CCD Platform, you must confirm that you have read and accept this Notice.

• You

When we refer to "you" in this document we mean any visitor to our website and/or platform which will include, our Chime Chare Partners (caregivers), potential and actual customers, suppliers and other people looking for information about our services.

The information below is also the policy we follow when processing your personal data.  So, if you do not accept this notice/our policy, you will not be able to access the CCD Platform.  

Please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy below by clicking here https://chimecare.co.uk/privacypolicy.

YES I consent to the installation of the Platform for the purposes of reviewing care service options and buying care services.

NO I do not consent to the installation of the Platform.

• How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us via contact@chimecare.co.uk  or phone 02080499776 (ext 2115) but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Also, it will not affect any processing of your personal data which we do based on another lawful basis, for example if we have entered into a contract to provide you with services.  If you enter into a contract with us to provide you with care services we will no longer be relying on consent as the lawful basis for our processing of your personal data.  

Details of our processing of personal data are set out below.

Cookies: you will have been asked to accept, manage or refuse cookies when you entered our website and/or CCD Platform.  Details of our Cookies policy is here: https://chimecare.co.uk/cookies.

• Introduction

This policy (together with our Web CCD Platform Terms of Use as set out at https://chimecare.co.uk/terms and any additional terms of use incorporated by reference into the Platform Agreement https://chimecare.co.uk/platformagreement , applies to our processing of your personal data further to your use of:

• our website.
• the CCD Platform hosted on our website, https://chimecare.co.uk ('CCD Platform'), once you have downloaded or streamed or accessed a copy of the Platform onto your mobile telephone, handheld device, computer or laptop (Device).

• any of the services accessible through the CCD Platform ('Services'), unless the Platform Agreement states that a separate privacy policy applies to a particular service, in which case that privacy policy only applies (e.g. those of payment merchants such as STRIPE).
• This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The CCD Platform is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
• Where you are providing personal data for a care recipient or family members please let them know that you are sharing their personal data with us and bring this policy to their attention.

This policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: https://chimecare.co.uk/privacypolicy .

[IMPORTANT INFORMATION AND WHO WE ARE]

[THE DATA WE COLLECT ABOUT YOU]

[HOW IS YOUR PERSONAL DATA COLLECTED?]

[HOW WE USE YOUR PERSONAL DATA]

[DISCLOSURES OF YOUR PERSONAL DATA]

[INTERNATIONAL TRANSFERS]

[DATA SECURITY]

[DATA RETENTION]

[YOUR LEGAL RIGHTS]

[GLOSSARY]

[DESCRIPTION OF CATEGORIES OF PERSONAL DATA]

• Important information and who we are

Chime Care Limited is the 'controller' and is responsible for your personal data (collectively referred to as "Chime" or, "we", "us" or "our" in this policy).

Our Chime Care Partners (or "Caregivers") access and process your personal data only using the CCD Platform and they are each a 'processor' of your personal data.  We have entered into a written agreement with each of our Chime Care Partners to ensure that your personal data is processed only in accordance with data protection legislation and this policy.

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

• Contact details:

Our full details are:

• Chime Care Limited
• Name of DPO: Mrs Kerry Lavallin
• Email address: Kerry.lavallin@chimecare.co.uk
• Postal address: F42/43 Crown House, Home Gardens, Dartford, DA11DZ
• Telephone number: 02080499776 (ext 2115)

We are always keen to improve our services and welcome any feedback on this policy and our compliance with it.  However, if we cannot resolve any issues with you directly relating to our processing of personal data you always have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

• Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 17 April 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next log onto the CCD Platform. The new policy may be displayed on screen and you may be required to read and accept the changes to continue your use of the CCD Platform or the Services.

It is important that the personal data we hold about you (and, if applicable, the care recipient if this is not you) is accurate and current. Please keep us informed if your personal data, or that of the care recipient to whom we provide care services, further to our contract with you, changes during our relationship with you.

• Third party links

Our CCD Platform may, from time to time, contain links to and from sites of our supplier networks, advertisers and affiliates. Please note that these third-party sites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through those sites or services. Please check these policies before you submit any personal data to those sites or use those services.

• Whose personal data will we process?

We will be processing your personal data, namely the personal data of the person who accesses our website, and/or logs onto our CCD Platform, either as a potential client or client or as a Caregiver ('CCD Partner'), and, where the client is not the intended care recipient, the personal data of the care recipient as well.  These people are all part of our CCD Community and we will also be processing the personal data of some or all of the following people;

"other Community members" where this means members of the care recipient's family (to whom we have been introduced via the CCD Platform) and our staff;

"Family Users" the client will be invited to designate certain family members of the care recipient who will then be given access to the "Family Hub", a secure area on the Platform where such family members can share information relating to the care recipient.  It is the responsibility of each designated family member to keep their password details secure and immediately notify us of any losses or breach.   Each Family User will have to accept this Privacy Policy and the Platform Agreement to access the Platform.

Each Client confirms in the Platform Agreement that where s/he is not the recipient of the Care Services the Client has obtained the consent of the recipient of the Care Services to share personal data as set out in this Privacy Policy.

• The data we collect about you

This will depend on who you are and why you are using the CCD Platform.  We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.
• Contact Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.

We do not process any financial data about our clients or care recipients.  (Payment information is given to the relevant third-party merchant.)

We do not hold any Client payment information. The CCD Platform does not have access to the Client's full card information at any point, only the Client’s name, type of card being used for payment, the last 4 digits of the long card number, the expiry date and the address to which the card is issued. STRIPE share with us an ID number and a fingerprint data number which they individually allocate to each Client.

We explain these categories of data below [See Section 23 – Description of Categories of Personal Data].

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 Platform 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.

We do collect certain types of Special Categories of Personal Data, namely health data about the care recipient, and pseudonymised biometric data.

We do not collect any information about criminal convictions and offences.

• How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us, about you or a care recipient, by filling in forms on the CCD Platform and/or our website, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the CCD Platform, buy any of our services or those of our Caregivers, make an in-Platform purchase, share data via an Platform's social media functions, enter a competition, promotion or survey, when you report a problem with the CCD Platform or our services or those of our Caregivers. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit our CCD Platform we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details available at https://chimecare.co.uk/cookiepolicy.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Device Data from the following parties:

• analytics providers such as Google based outside the UK;
• advertising networks such as Facebook based inside OR outside the UK; and
• search information providers such as Google based inside OR outside the UK.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as STRIPE based inside OR outside the UK;
• Identity and Contact Data from data brokers or aggregators based inside OR outside the UK;
• Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK;
• credit agencies; and
• Unique application numbers. When you want to install or uninstall a service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

• Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of our website and the CCD Platform and to remember your preferences. This helps us to provide you with a good experience when you use the CCD Platform and also allows us to improve the CCD Platform. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy available at https://chimecare.co.uk/cookiepolicy.

• How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

See Section 20 Glossary: Lawful Basis to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent or we have a legitimate interest to do so. You have the right to withdraw that consent at any time by contacting us.

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

• Purposes for which we will use your personal data

• Disclosures of your personal data

When you choose to provide us with your personal data, we may also need to share your personal data with the third parties set out below, for the purposes set out in the table "Purposes for which we will use your personal data".  (Where we do not have another legal basis for sharing your personal data with these third parties we will ask for your consent.)

• External Third Parties, as set out in the Glossary.
• Specific third parties such as Meta, Klaviyo, SendGrid, Stripe, HubSpot, Calendly may be utilised to handle your personal data for purpose mentioned above in Section 14 Purposes for which we will use your personal data.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change applies to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

• International transfers

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, contact contact@chimecare.co.uk.  
• where we use certain service providers overseas, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK. For further details, contact@chimecare.co.uk.

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

• Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our CCD Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Details of procedures and features:

Change password every 12 months

No one can access your personal data with our knowing or your permission

We don’t unnecessarily disclose supply your personal data to 3^rd parties

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

The data security measures we have in place include:

Cookie based authentication

• Users are granted an authentication token after they have logged into the application which is stored in the browser’s cookies, removing the need of forwarding authentication information in every server request (thus diminishing a potential credential stealth threat).
• Every resource endpoint requires this cookie to be set, so methods / endpoints that require a valid user authentication will produce an unauthorized error if the requester doesn’t have a valid one (almost all requests except the login require this token).

Role based restrictions

• Request are verified with the role provided by the application to the user, allowing access to only certain groups (ex. an internal account register can be made only a user with administrative roles).
• The user interface also considers user permissions based on the assigned access level granted by the application after the register. Certain functionality is disabled for user-roles that (from a business logic level perspective) shouldn’t be able to read or modify / alter the state of specific items.
• Page access to URLs within the application verify and block the user’s permissions when necessary. (ex. a caregiver user cannot access the pages displayed for an administrator)

Data security

• The passwords of each user are hashed before being saved in the database. These are saved either at register operations or change password actions. In a login attempt the password input is hashed, pushed through a secure connection and checked against the one stored in the application database. Accounts are also blocked after 5 unsuccessful login attempts
• SQL Injection is also handled throughout the application business layer, having no direct sql statements called and specific input type requirements made for each method.

SSL Certificate

• The hosting server will benefit of secure HTTPs communication, via SSL certificate. Primarily this means that all the requests, communication between the clients (user browsers) and the web server will be encrypted, making the communication between them trusted and secure.

• Data retention

The retention periods will vary for different types of your personal data.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Regulatory laws require us to keep certain information for 7 years after we cease supplying a care recipient with care services.

In some circumstances you can ask us to delete your data: see Section 19 Your legal rights below for further information.

In some circumstances we will 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.

In the event that you do not use the Platform for a period of 24 months then we will treat the account as expired and your personal data may be deleted unless you contact us to let us know we should keep your information on file.

• Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. Further information about these rights is set out below. [LINK to glossary]

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

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at contact@chimecare.co.uk.

• Glossary

"Caregiver"/"CC Partner" is the professional, supplier of Care Services who is supervised by us and who is using our CCD Platform to advertise and sell their Care Services, and who has entered into a contract with us to meet our Minimum Standards and who will provide a care recipient with care services on the terms set out in the Caregiver Contract

"Client" means the person who uses the CCD Platform to purchase Care Services, who may or may not be the recipient of the Care Services and who is over 18.

Lawful basis means Consent, or Legitimate Interest or Performance of Contract or Comply with a Legal Obligation as further defined below:

• Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
• Legitimate Interest means 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 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Platform Agreement means the agreement between Chime Care Limited and clients for care services purchased via the CCD Platform.

Services means any of the services accessible through the CCD Platform.

• Third parties

External third parties

Service providers such as the CC Partners based in the UK, payment merchants based in Ireland and IT service providers and system administration providers, based in USA each of whom acts as processors.

Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or controllers based in the UK who require reporting of processing activities in certain circumstances.

• Your legal rights

You have the right to:

• 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.
• 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.
• 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 local law. 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.
• 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.
• 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 do not 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.

• 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.
• 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.  Also, if we have another lawful basis on which we may process your personal data the withdrawal of consent may not prevent us from processing your personal data further.

• Description of categories of personal data

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: billing address, delivery address, email address and telephone numbers.
• Financial Data: bank account and payment card details.
• Transaction Data: includes details about payments to and from you and details of in-Platform purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
• Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content, check-ins, submissions.
• Profile Data: includes your username and password, in-platform purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Platforms or your visits to any of Our CCD Platform including, but not limited to, traffic data and other communication data whether this is required for our own billing purposes or otherwise and the resources that you access.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

"User" is any person that uses the CCD Platform in any capacity, including but not limited to Clients, Caregivers and website and CCD Platform visitors.

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