Special Category Data	No special category data is collected
Personal information	To contact ADL Smartcare through the www.adlsmartcare.com website we require your first name, last name, email, organisation name (if applicable), country, telephone number and the reason for your interest in our services. We optionally ask for your job title, type of organisation, size of organisation, sector and interests. Personal Information Legal Basis – Explicit Consent When you register for the service, you give your explicit consent to the processing listed above for providing information and advice services. You can remove this consent by sending a request through our dedicated GDPR form or closing your account.
Communication and promoting a secure service	We will use your contact details to respond to any requests you generate from the ADL Smartcare services. We will use your contact details to provide updates on the service such as changes to the 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 collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, operating system, mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information. 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 service to improve the service and provide support. We also send you surveys about our Services, which you can opt to completion a voluntary basis. The use of this data is necessary to ensure our interests in improving the tools and platform available to our users through using better technology, user design and communications

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 data 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.