Privacy Policy

This privacy notice sets out how CareBrain Limited ("we", "us" and "our") uses and protects your personal data.

This privacy notice gives you information about how we collect and use your personal data, including any data you may provide when you use our website (including our web application) and mobile application software (App), or when we provide services to your employer. This privacy notice does not apply to personal data that we process as a data processor on behalf of our clients. For further information about how such data is processed, please contact (or refer to the privacy notice of) the relevant data controller. If you have any questions about this privacy notice, including any requests to exercise your legal rights (section 9), please contact us using the information set out in the contact details section 10. Our website and App are not intended for children and we do not knowingly collect data relating to children.

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title and job title.
Contact Data includes address, work address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our website and App.
Profile Data includes your username and password.
Usage Data includes information about how you interact with and use our website, App and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website or App feature in order to analyse general trends in how users are interacting with our website to help improve our website, App and service offering.

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data when you communicate or interact with us. This includes personal data you provide when you:

request further information about our services;
register as a user on our website or App; or
communicate with us, including via email.

Automated technologies or interactions. As you interact with our website or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie notice [LINK] for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources including the following:
Identity Data, Contact Data, and Usage Data from your employer;
Technical Data is collected from the following parties:

analytics providers such as Google based outside the UK; and
search information providers and advertising networks such as Facebook, LinkedIn, Instagram, X and other social media companies which may be based inside oroutside the UK.Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to provide services. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example, for marketing purposes in certain circumstances.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
To permit you to install the App and to register as a user	Identity Contact	Legitimate interests (to deliver our App and to enable us to provide services to our clients)
To provide services to our clients	Identity Contact Profile	Necessary for our legitimate interests (to enable us to provide services to our clients)
To contact you and communicate with you regarding our services	Identity Contact Marketing and Communications	Necessary for our legitimate interests (to enable us to provide information about our services and to communicate with you)
To manage our relationship with you and/or your employer	Identity Contact Marketing and Communications	Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and manage our relationship with you and/or your employer)
To enable you to complete a survey	Identity Contact Marketing and Communications	Necessary for our legitimate interests (to study how our services are used, to develop them and grow our business)
To administer and protect our business, website and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical Profile	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation
To deliver relevant website and App content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how our services are used, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, App, services, client relationships and experiences and to measure the effectiveness of our communications and marketing	Technical Usage	Necessary for our legitimate interests (to define types of clients for our services, to keep our website and App updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about services that may be of interest to you based on your Profile Data	Identity Contact Technical Usage Profile Marketing and Communications	(a) Consent, having obtained your prior consent to receiving direct marketing communications; (b) Necessary for our legitimate interests (to carry out direct marketing, develop our services and grow our business); Please see 'Direct marketing' below for further information about our legal basis for marketing communications.
To carry out market research through your voluntary participation in surveys		Necessary for our legitimate interests (to study how our services, website and App are used and to help us improve and develop our services)
To fulfil our legal obligations, and to establish, exercise or defend legal claims	Identity Contact Marketing and Communications	(a) Necessary for our legitimate interests (to allow us to fulfil our legal obligations and to protect and defend legal claims); (b) Necessary to comply with a legal obligation

We may ask for your consent for direct marketing communications. If we ask for your consent and you provide consent, this will be our lawful basis for marketing communications. In other cases, and provided we are able to do so under applicable data protection law, we may rely on legitimate interests to send marketing communications. In either case, you can opt out of marketing. Please see below for further information. We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which services and offers may be of interest to you or your employer so that we can then send you relevant marketing communications.

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the contact details in section 10. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or service purposes.

We use cookies (small files placed on your device) and other tracking technologies on our Website and App to improve your experience and our development of our Website and App. 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 notice [LINK].

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

Your employer.
Our suppliers and service providers.
Courts, law enforcement, regulatory authorities and government officials.
Lawyers, insurers and other advisors.
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 happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as UK law. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it. Currently, we do this by transferring your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, Ireland.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data: see 9 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.

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "subject access request").
Request correction of the personal data that we hold about you.
Request erasure of your personal data in certain circumstances.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests).
Object any time to the processing of your personal data for direct marketing purposes (see4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data).
Request restriction of processing of your personal data.
If you wish to exercise any of the rights set out above, please contact us using the details set out in section 10.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your 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.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you have any questions about this privacy notice or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: enquiries@carebrain.ai
Postal address: 6th Floor 9 Appold Street, London, United Kingdom, EC2A 2AP

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

We keep our privacy notice under regular review. This version is dated [DATE]. When we make changes to our privacy notice, historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

Our website and App 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, plug-ins or applications and are not responsible for their privacy statements. When you leave our website or App, we encourage you to read the privacy notice of every website or application you visit.

Introduction

1. Important information and who we are

Privacy notice

2. The types of personal data we collect about you

3. How is your personal data collected?

4. How we use your personal data

Legal basis

Purposes for which we will use your personal data

Direct marketing

Third-party marketing

Opting out of marketing

Cookies

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

How long will you use my personal data for?

9. Your legal rights

No fee usually required

What we may need from you

Time limit to respond

10. Contact details

11. Complaints

12. Changes to the privacy notice and your duty to inform us of changes

13. Third-party links