Privacy Policy for the use of the LifeCurve™ App, 1st March 2020

Overview

For over 18 years, ADL Smartcare has helped people access specific information and advice to improve their independence and live life better, for longer. We have always taken the responsibility of looking after personal data very seriously and this Privacy Policy explains what personal information we collect and process.

The collection of personal data is covered by the General Data Protection Regulation (GDPR), which sets out clear rules for organisations holding personal information and the rights of individuals whose personal information is held by them. We have developed our systems and processes to ensure that we comply with or exceed these standards and obligations.


Privacy Policy Summary

This service helps you understand how you are ageing and provide tasks to help improve or maintain your position on the LifeCurve™, which uses an evidence-based independence scale. We store your LifeCurve™ assessments and how you interact with the tasks linked to your LifeCurve™ position.

Your data is securely synced from the app to our secure servers based in the UK. You can also connect to authorised partners who would like to help you improve your position through their own tasks or to see how you are doing to support any service they provide you e.g. a rehabilitation service.

You are in total control of who you connect to. We are the Data Controller for this service and only those partners you connect to can see your LifeCurve™ activity and how you interact with their tasks. No one else can see your personally identifiable data.


Full Privacy Policy

Special Category Data

The LifeCurve™ App collects your LifeCurve™ position, stores it and syncs it to your Passport account stored on ADL Smartcare secure servers This includes previous LifeCurve™ positions and any interaction with the tasks contained to support your healthy ageing and living a better life for longer.

To use the app, you expressly give your consent for the processing of your personal and special category data.

Personal information

To register on this service, you are required to create an ADL Passport account which is a single sign on service for all of ADL Smartcare services. To register we require your first name, last name, post code, country and an email address.

We also record your current ageing position on the LifeCurve™, which has been identified based on research from Newcastle University and ADL Smartcare Research such as the ability to cut your toe nails.

We record tasks you save to complete at a later date such as reactivation exercises and activity relating to those activities, such as completing or removing a task from your saved items.

Personal Information Legal Basis – Explicit Consent

When you register for this service, you give your explicit consent to the processing listed above to access information and advice services. You can remove this consent by sending a request through our dedicated GDPR form located within the service or closing your account.

Personal Information Legal Basis – Explicit Consent
When you register for this service, you give your consent for us to use your non-identifiable data for the purposes of ethical research into ageing and healthy ageing at our research base in Newcastle University. You can opt out at any time by changing permissions in your account
Personal Information Legal Basis – Explicit Consent

When you connect to a LifeCurve™ Partner from within the App, you are providing consent for us to share your LifeCurve™ assessment (both current and historic) with the designated partner and any interactions with that partner’s tasks. You can remove this consent at any time by disconnecting the link with the partner within the App.

Communication and promoting a secure service

The LifeCurve™ app can send (with your permission) push notifications to remind you to carry out another LifeCurve™ or complete your tasks. We will use your contact details to respond to any support requests you generate from using ADL Smartcare services. We will use your contact details to provide updates on the ADL Passport service such as changes to our privacy policy.

We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our policies.

Communication Legal Basis – Legitimate Interest

We send users important notices regarding the service such as any service issues or security concerns. ADL Smartcare has a legitimate interest in sending these emails to keep you up to date about any matters which may affect your experience of the service.

Analytics and navigation

We currently record App downloads and uninstalls plus any error reports which are provided by the app stores such as Apple, Google and Amazon. There are currently no other analytical data collection tools within our App.

We record your LifeCurve™ assessment activity which is synced to your account on ADL Smartcare's secure servers and any tasks you save to action from the App.

Analytics and navigation Legal Basis – Legitimate Interest

Ensuring the best possible experience for the service we use data about you and your use of our services to improve the service and provide support. We also send you surveys about our services, which are voluntary to complete. The use of this data is necessary to ensure our interests in improving the tools and platform available to our users through better technology, user design and communications.

Interaction with external social networks and platforms

When you log in you are able to share a task on a social network such as Facebook or Twitter. The pp uses your mobile's in-built sharing feature and you do not need to provide any social network log in credentials.

Support ADL Smartcare's Healthy Ageing across the UK

We and our users are proud to support ADL Smartcare's research into improving ageing across the UK and internationally.

If you want to support this research then tick the opt in box when you register. Your anonymised data will then be used to help improve ageing for future generations.

Your data is anonymised so you will not be individually identified as a participant of the research. However, by joining you will be contributing valuable data which can be used to support research into the ageing process and how better outcomes can be achieved to promote healthy ageing and happier longer lives.

You can opt in during the registration process and once registered, you can opt in or out at any time within your account area.

ADL Smartcare's Research facility is based at the National Innovation Centre for Ageing at Newcastle University. Together we can make a positive impact on long term ageing and support healthy ageing across the UK.

We would like to thank you for your contribution to helping future generations confident in the knowledge that your identity has not been used.

Personal Information Legal Basis – Explicit Consent

When you register for this service, you provide consent for us to use your non-identifiable data for the purposes of ethical research into ageing and healthy ageing at our research base in Newcastle University. You can opt out at any time by accessing your account within the service.

We use the information we collect for the following purposes:

Maintain and provide you with an effective service

We are able to deliver the services as described in our Terms of Use contract with you. Information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data.

We use technology to collect information indirectly - such as your IP address and mobile device identifier and how much time you spend on the site. This is commonplace across all internet services to enable the investigation of issues such as malicious use. This information is then kept in our internet access logs.

We collect information directly from you in a number of ways. One way is by using cookies. Cookies are small data files that save and retrieve information about your visit to our website, such as how you entered our website, how you navigated through the website and what information was of interest to you. This information is collected for a number of reasons, for example, to help develop the website and associated services.

The cookies we use identify you as a number. If you are not comfortable about the use of cookies, you can disable them by changing the settings in the preferences or options menu in your internet browser. Disabling cookies, however, may affect our ability to provide services to you. If certain cookies are disabled you may not be able to access the service. See our Cookie Policy for more information on the cookies we use. Site features include storing whether to show or hide the accessibility bar.

Data is collected when you perform an assessment through the website. This is collected in order to provide healthcare related guidance and matching to advice, equipment, information and/or services. It can include, your Instrumental Activities of Daily Living capabilities, your record of performing the recommended activities and any answers to questions to support the matching of solutions to your needs for a given area of interest such as struggling to get up and down from the bottom of the bath.

Ensuring the best possible experience for the service we use data about you and your use of our service to improve and develop a better solution; to improve how you get to the advice faster; to drive our research and development; and to better understand our users and how they are ageing. We also send you surveys about our services, which are voluntary to complete. The use of this data is necessary to ensure our interests in improving the tools and platform available to our users through better technology, user design and communications.

We never use your identifiable personal to support the ethical research into ageing and improving healthy ageing for others. However, we do use your anonymised data for this purpose and you can opt in to contribute to future research by ticking the appropriate box when you register or by going to your account and changing your permissions.

Communicate with you

We use your information when we need to send you service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in. We would never user your email address for marketing purposes by third parties.

Promote security and safety

We use the information we collect to promote the safety and security of the services, our users, and other parties. For example, we may use the information to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

We use cookies and similar technologies for the purposes described above. For more information, please read our Cookie Use statement.

We use the following service providers in the administration and delivery of the service:

Data Controller Data Processor Reason Data
ADL Smartcare Limited Infrastructure Provider Dedicated ultra-secure infrastructure for hosting the software as a service. Data centre for the service where personally identifiable data is stored securely in a secure former nuclear bunker in the UK.
ADL Smartcare Limited Google Analytics Website performance and usage information IP address and usage of the service
ADL Smartcare Limited Post Code Lookup service Provide address and Local authority of a given postcode - used for registration of an account holder and any associated profiles. Post code only (the user is not identified and the third-party service does not store information)

We also may disclose your information if required by law, requested by law enforcement authorities or to enforce our legal rights. We may share your information in connection with a sale or reorganisation of ADL Smartcare, but in any such case, the terms of this Policy will continue to apply.

We recognise that your personal data belongs to you and we don’t wish to use it in way that you don’t want us to.

You can exercise a number of rights regarding our use of your data from within the service such as accessing a copy of the information we have on you. This is for yourself or any profiles you created for a friend/relative. You can correct any information we have on you through the account area of the services. You can access a copy of your name and address details in a common, machine-readable format such as Comma-Separated Values (CSV) to share with another supplier.

You can exercise a number of rights regarding your data by using the GDPR dedicated contact form found within the service or by contacting the Data Protection Officer.

  • You can make a request for us to delete your data, however we may be prevented to do this if it impacts our ability to defend a claim against the advice we provide or if it is detrimental to you or the public’s health.
  • You may withdraw your consent for ADL Smartcare to collect and process data about you at any time
  • You can ask us to restrict the processing of your data.

Please note that some of these rights aren’t absolute - for example, we may not be able to forget you if we have to keep some of your data to comply with the law—but we’ll evaluate your request in accordance with applicable data protection laws.

The Data Protection Officer and ADL Smartcare will respond to your request within one month of receiving it.

Also, note that you have the right to lodge a complaint with the UK Information Commissioner’s Office or the supervisory authority in your country of residence or place of work.

You are not required to provide personal data to us however, your failure to do so may affect our ability to provide some of the services you may request. For example, we are unable to save an assessment if you do not open an ADL Smartcare account.

You can make a request to have your data removed by using the dedicated GDPR compliant support forms found in the account area of the service.

We keep your account information, like your name, email address and password for as long as your account is in existence so we can operate your account. As our services support independence and healthy ageing over the years, it is important you are able to access your historic data to support your well-being. You obviously have the option to request your account to be deleted using our GDPR compliant form, found in the account area. We keep your personal data in an identifiable form for as long as we have a legitimate reason to use the data and as required by law.

We have always worked hard to put in place measures to protect your data and keep it sage. We use a combination of technical, physical and operational measures to maintain your security of data including encryption.

Changes to this policy

We update this Policy from time to time, so please review this Policy regularly. By continuing to use this service after it has been updated it will be deemed that you have consented to the updated Privacy Policy. If not, you may choose to cancel your account.

Please visit our archived privacy policies for previous versions.

ADL Smartcare Privacy policies

You can see the full list of privacy policies for our services by visiting the below links:

Who we are and how to contact us

ADL Smartcare Limited is a private company limited by shares incorporated in England and Wales Company Number: 04456225. If you have a general enquiry you can contact ADL Smartcare via info@ADLSmartcare.com or by writing to ADL Smartcare, Electric Works, Sheffield Digital Campus, 3 Concourse Way, Sheffield, S1 2BJ, United Kingdom.

ADL Smartcare is the Data Controller of this service.

How to contact us if you have any questions about your personal information

The Data Protection Officer can be contacted at privacy@adlsmartcare.com or

ADL Smartcare,
Electric Works,
Sheffield Digital Campus,
3 Concourse Way,
Sheffield,
S1 2BJ

Our GDPR compliant support form can be found here

Further information and help

If you have any questions then please review the privacy help area with in the service or contact the Data Protection Officer on privacy@adlsmartcare.com