LifeCurve™ App Privacy Policy (Released: November 2022)
Overview
Since 2002, 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 New Zealand Privacy Act 2020 and UK 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 or exceed these standards and obligations.
Privacy Policy Summary
This service provides you with a single sign on to one or more of ADL Smartcare’s services, using the same account. We only require your name, email address or phone number, ethnicity, post code and age range. ADL Smartcare is the data controller for this service (as defined in the GDPR)
This service is integrated into the LifeCurve™ to help you live better for longer. It uses independent professional best practice advice collected since 2002 from Allied Health Professionals and Occupational Therapists, to find specific advice based on your answers to one or more questions for an area of need such as struggling to bathe.
The LifeCurve™ is an evidence-based measurement framework developed in conjunction with Newcastle University, UK for understanding ageing. Research has shown that people lose the ability to complete activities of daily living (ADLs) in a particular order. By using these 15 ADLs, combined with 4 fitness and strength markers, a person can position themselves on the LifeCurve™ to see how they are ageing.
Once we know where a person is on their ageing journey, we can map them to activities, services and products that will help them either maintain, or even recover, their current abilities. The LifeCurve™ and the evidence behind the service continues to develop through the anonymised LifeCurves taking place across the world. Together we can help future generations and their ageing.
ADL Smartcare as the Data Controller for this service (as defined in the GDPR) which has been commissioned by Te Whatu Ora / Hauora a Toi Bay of Plenty and authorised license holders from Te Whatu Ora / Hauora a Toi Bay of Plenty can access your personally identifiable activity in their segregated and secure Staff Access Website. Te Whatu Ora / Hauora a Toi Bay of Plenty license holders will only use the information they have access to in order to support your health and well-being and monitor your interactions with the LifeCurve™.
ADL Smartcare Limited has invested in providing and storing data collected through these services on New Zealand compliant infrastructure, based in Australia.
Please note that Te Whatu Ora / Hauora a Toi Bay of Plenty is committed to Te Tiriti o Waitangi. Te Whatu Ora / Hauora a Toi Bay of Plenty Position Statement on Te Tiriti o Waitangi, Equity and Racism can be found here:
https://www.bopdhb.health.nz/media/admjqagh/te-tiriti-o-waitangi-health-equity-and-racism.pdf
Full Privacy Policy
What types of information do we collect? |
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| Special Category Data |
The LifeCurve™ collects and stores your LifeCurve™ position, past LifeCurve™ positions and also any interaction you have with the tasks. To use this service and store your data against your account, you expressly give your consent for the processing of your personal and special category data. Personal Information Legal Basis – Explicit ConsentWhen you register for this service, you give your explicit consent for us to process your data to provide information and advice services. You can remove this consent by sending a request through our dedicated NZ Privacy Request form or closing your account. |
| Support Healthy Ageing across New Zealand with the New Zealand National LifeCurve™ Research Partnership |
Support the NZ National LifeCurve™ Research PartnershipOur users are proud to support the New Zealand (NZ) National LifeCurve™ Research Partnership’s research into improving ageing across New Zealand. We are committed to ensuring future research aims to support health equity. You can opt in to the NZ National LifeCurve™ Research Partnership’s healthy ageing research during registration, where your anonymised data is collected as part of this service to support and improve ageing for current and future generations. The New Zealand National LifeCurve™ Research Partnership will improve the evidence and learning on healthy ageing, living better for longer and impacting the lives of everyday people. Together we can impact long-term ageing and support healthy ageing across New Zealand. The Te Whatu Ora / Hauora a Toi Bay of Plenty Clinical School, ADL Smartcare Limited and the University of Auckland will be part of this partnership and have access to your anonymised data. All of the data will be anonymised, so it will not be possible to provide you with an individual response from any results from future research, or to have future access to this information and request corrections to mistakes. However, general information based on healthy ageing research can be provided. New Zealand National Research Partnership for LifeCurve™ operationsThe information we collect, including your personal information, will be stored within New Zealand compliant infrastructure in Australia, as agreed with the Ministry of Health, New Zealand. The anonymised data will be stored in a databank in Australia. The databank is operated by ADL Smartcare Limited and has extensive measures to protect your data and keep it safe. We use a combination of technical, physical and operational measures to maintain security of your data, including encryption. The anonymised data in the databank will be stored for as long as we consider it is appropriate for understanding ageing across ethnicity groups and across generations. The NZ National LifeCurve™ Research Partnership will review the data retention considerations as part of the annual Information Governance review. The NZ National LifeCurve™ Research Partnership will agree one or more research projects which will follow strict research protocols, including review by an ethics committee as well as Māori review. These projects will then nominate one or more researchers to have access to the NZ National LifeCurve™ Research Partnership data. They will then have secure and limited access to the anonymised data. Any use of Māori specific collective data will be transparent and only used for the benefit of Māori. If you have any questions about the NZ National LifeCurve™ Research Partnership you may contact the NZ Privacy Officer at ADL Smartcare Limited. The NZ Privacy Officer for ADL Smartcare can be contacted at privacy-nz@adlsmartcare.com The NZ Privacy Officer for the Te Whatu Ora / Hauora a Toi Bay of Plenty can be contacted at:
The Privacy Officer The anonymised data we processThis research may include basic information such as your LifeCurve™ level, ethnicity, age and gender. It is possible that future research could one day help people in the same groups as you. Research protocols and a review by an ethics committee as well as Māori review will help manage potential risks on how the anonymised data is used. However, it is also possible that research findings could be used inappropriately to support negative stereotypes, stigmatize, or discriminate against members of the same groups as you. The NZ National LifeCurve™ Research Partnership would like to thank you for helping current and future generations to live happier and healthier lives and you can be confident that you are never identified. Personal Information Legal Basis – Explicit ConsentDuring registration you have the option to provide consent for the NZ National LifeCurve™ Research Partnership to use your non-identifiable LifeCurve data to support future research, aimed at improving ageing. Te Whatu Ora / Hauora a Toi Bay of Plenty Clinical School, ADL Smartcare Limited and the University of Auckland will be part of this partnership. The anonymised data will be used for unspecified future research into healthy ageing with aims that can include improving the wellbeing, ageing and health outcomes of individuals and Māori. No identifiable data will be used. You can opt out at any time by accessing your account within the service. |
| Personal information |
To register for this service, you are required to create an account. To register we require your first name, last name, post code, age, gender and ethnicity, country and an email address or phone number. Following a LifeCurve™ assessment, your current ageing position on the evidence based LifeCurve™ will be saved and your answers to the 19 questions, such as the ability to cut your toenails will be saved. Tasks you save to complete at a later date such as reactivation exercises and actions relating to those activities such as completing or removing a task from your saved items. Personal Information Legal Basis – Explicit ConsentWhen 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 NZ Privacy Request form or closing your account through the MyAccount area of the website. Personal Information Legal Basis – Explicit ConsentWhen you register for the service, you provide consent for ADL Smartcare Limited to use your non-identifiable data for the purposes of ethical research into ageing and healthy ageing at our research base in Newcastle, United Kingdom. Identifiable data will remain within the New Zealand compliant infrastructure. Your information will be protected in the United Kingdom to the same standard as it is in New Zealand. The resulting research will support further improvements in the LifeCurve™ framework, which is used by people around the world with aims that can include improving the wellbeing, ageing and health outcomes of individuals. Personal Information Legal Basis – Legal DutyWe share your data with Te Whatu Ora / Hauora a Toi Bay of Plenty that we work with and we will retain your data to the extent required to comply with our legal obligations. We employ safeguards, such as a formal data governance programme which will include Māori representation and have implemented robust security measures, to protect your privacy. |
| Communication and promoting a secure service |
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 InterestWe 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 our 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 InterestTo enable you to have the best possible experience whilst using our services we use data about you and your use of our service to improve the services we offer 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 are logged into the LifeCurve™ App you are able to share a task to a social network such as Facebook or Twitter. The app uses your mobile's in-built sharing feature and you do not need to provide any social network log in credentials. |
How we use your information
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. We collect information about your use of our site including details of your visits within the ADL SmartCare APP 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 and the LifeCurve™, 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, LifeCurve™ 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.
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 will 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.
How we share your information
We use the following service providers in the administration and delivery of the service:
| Data Controller | Data Processor | Reason | Data |
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| 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 in New Zealand compliant infrastructure in Australia. (As agreed with the Ministry of Health, New Zealand) |
| 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.
Your rights to access and control your personal data
We recognise that your personal data belongs to you and we don’t wish to use it in any 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 NZ Privacy Request form found within the service or by contacting the NZ Privacy 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 privacy laws.
The NZ Privacy Officer and ADL Smartcare will respond to your request within 20 working days of receiving it.
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 NZ Privacy Request support forms found in the account area of the service.
Data Retention
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 NZ Privacy Request 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.
Information Security
We have always worked hard to put in place measures to protect your data and keep it safe. We use a combination of technical, physical and operational measures to maintain your security of data including encryption.
Breaches of your privacy
We take our privacy responsibilities seriously. In the unlikely event that a suspected or actual breach of your personal data occurs, we will investigate the breach. We will notify you and the Privacy Commissioner if we reasonably believe that the breach has caused you serious harm, or is likely to cause you serious harm.
Changes to this policy
We update this Policy from time to time, so please review this Policy regularly. Any changes to the policy will be emailed to you and/or shown when you next log into the service. 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.
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.
ADL Smartcare is the Data Controller of this service.
How to contact us if you have any questions about your personal information
The NZ Privacy Officer can be contacted at privacy-nz@adlsmartcare.com
Further information and help
If you have any questions then please review the privacy help area with in the service or contact the NZ Privacy Officer on privacy-nz@adlsmartcare.com
AWESSoM project privacy policy, for the use of the LifeCurve™ App (Released: 24 March 2021)
University of Auckland AWESSoM project, Faculty of Medicine and Health Sciences, School of Population Health Privacy Policy (herein after referred to as AWESSoM project):
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Data Protection Officer for LifeCurve Partner:
ADL Smartcare is the Data Controller and the University of Auckland will become an Independent Data Controller if they securely download and save data into their systems. The Data Protection Officer for the University of Auckland can be contacted at +64 9 923 7746
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No Advertising or Marketing
ADL Smartcare or the AWESSoM project does not have any third-party advertising within the service and we will not share your information to third parties for marketing purposes. The AWESSoM project may send you a push notification (if this is enabled) and/or emails to gather feedback on the service and LifeCurve tasks they provide.
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Personal data collected
The AWESSoM project will have access to 3 areas of data; Personal contact details, your LifeCurves and any LifeCurve Tasks and utilisation of tasks you interact with.
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Personal information
To register for the service, we need your first name, last name, email address, postcode. You can also share other personal information such as address details and data of birth by entering this in the Account area.
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LifeCurve
The AWESSoM project will have secure access to your LifeCurve’s completed after you connect to them. This includes your ageing position on the LifeCurve, the answers to the LifeCurve and any times entered.
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LifeCurve Tasks by the AWESSoM project
The AWESSoM project in addition will have access to any task the AWESSoM project has added to the service such as 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. The AWESSoM project will not have access to any other data you enter through the ADL Smartcare service apart from what is listed above.
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Use of personal data collected
The AWESSoM project will use your LifeCurve and any tasks you have accessed by the AWESSoM project for the following purpose:
For research purposes within the AWESSoM (Ageing Well Through Eating, Sleeping, Socialising and Mobility) study. This research seeks to answer the question ‘does participant use of the LifeCurveTM App make a difference in maximising independence, social connection, quality of life, wellbeing and function for older people living in the community’.
You data will be collated, analysed and anonymised to generate a report.
The legal reasons for using your data are explicit consent. When you connect to the AWESSoM project, you give your explicit consent to the processing. You can remove this consent by disconnecting from the AWESSoM project.
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Data Sharing
The AWESSoM project will not share your data with any other organisation without your consent. However, anonymised data may be used as detailed in the Patient Information Sheet and Consent Form.
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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.
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Where Are We Sending Your Data?
The service is hosted on a dedicated, segregated cloud-based Australian infrastructure site. The site provider is known as The Bunker using Microsoft Azure. Your identifiable information does not leave this location unless as specified earlier in this privacy statement or as per the patient information sheet and consent form.
The AWESSoM project will access your data through an secure interface provider for Te Whatu Ora Hauora a Toi Bay of Plenty. Any identifiable data is held at the University of Auckland during the study in a password protected computer file. All coded information is entered into a password protected computer and any information sent electronically is done so through a secure server. All storage will comply with local and/or international data security guidelines. All reported data will be anonymised.
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How long do we keep your data?
For at least ten years, it is then destroyed.
Further information and help:
If you have any questions then please use the following contact details for the University of Auckland
0800 222 848.
You can also review the privacy help area with in the service or contact the ADL Smartcare’s Data Protection Officer on privacy-nz@adlsmartcare.com
