Who we are
For the purpose of the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“DPA 2018”), the data controller is Nourish Care Systems Limited, a company registered in England and Wales under company number 07556262, with a registered office at Floor 3 Dean Park House, 8-10 Dean Park Crescent, Bournemouth, England, BH1 1HL.
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If You have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact Our DPO using the details set out below.
How to contact Us
Email Our Data Protection Officer at Compliance@nourishcare.co.uk
Call us on +44023 8212 3163
Or write to us at:
Nourish Care Systems Limited
Floor 3 Dean Park House,
8-10 Dean Park Crescent,
Bournemouth,
England,
BH1 1HL.
Purpose of this Privacy Policy
Here at Nourish Care we take your privacy rights very seriously and we seek to ensure the highest standards of compliance. We fully comply with all applicable data protection laws, including: (i) the General Data Protection Regulation (“GDPR”) and other applicable European Union data protection laws; (ii) the UK Data Protection Act 2018 (“DPA 2018”) and other applicable UK data protection law (“Data Protection Legislation”).
Our Privacy Policy explains how we collect, use, disclose and retain your Personal Data and how you can protect your privacy when you use the Site.
It is important that you read this Privacy Policy together with any other privacy notice, our fair processing notice we may provide on specific occasions (e.g. when we our collecting our processing Personal Data about you), so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements other notices and is not intended to override them.
Changes to Our Privacy Policy
This is our Privacy Policy, and it supersedes any earlier version. Please note that we regularly review our Privacy Policy and from time to time we will update and amend the policy accordingly.
We will always post any changes to our Privacy Policy on this section of our Site. If we make changes to the way that we use your Personal Data, we will inform you via email our similar means.
If you have any queries or complaints in relation to this Privacy Policy, please contact us using the “how to contact Us” section above, we will always value your feedback. You can raise a complaint by following the procedure under the “complaints” section of this Privacy Policy.
Protecting your privacy and identity
We use appropriate administrative, physical and technical safeguards to protect your Personal Data from loss, theft, unauthorised access, disclosure, modification or destruction. For example, we train our personnel to protect your privacy and require them to comply with our policies and procedures that protect your Personal Data. 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 contracted to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breaches. We use computing systems in secure facilities to store your Personal Data in an encrypted form. Data between our servers and a client browser is transferred via HTTPS/TLS. This means that your Personal Data is encrypted between the device and our external host storage.
We use best practice to ensure that data minimisation principles are met. We only collect Personal Data we need for our specified purposes. We ensure that Personal Data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. We have controls and processes in place to challenge, assess and review current and proposed changes to data processing.
Personal Data, Special Category Data and non-Personal Data
“Personal Data”, our personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
“Special Category Data” means Personal data that includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offences.
We may collect, use, store and transfer different types of Personal Data and non-Personal Data about you which we have grouped together as follows:
-
Registration Data:We process the following registration data;
- email address
- postcode/eircode
- telephone number
- information about where you heard about Nourish Care
-
Customer’s Users Data:Personal Data collected and generated when a Customer’s User opens a user account, manages the services we provide to the Customer and interacts with us including:
- date of birth
- email address
- username
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Technical and Location Data:We will collect and store time zone and country upon registration, then all relevant IP addresses and other end users accessing the site along with their login data, browser type and version, operating system and platform, and other technology on the devices they use to access our site.
If You fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
How we collect your Personal Data and why do we have it
We will only use your Personal Data where the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your Personal data although we will seek your consent, or give you the chance to opt-out in light of our latest communication, before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which We will use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use 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. Should the purpose for which we will use your Personal Data change, and consent is our lawful basis for processing, you will be informed, and consent re-obtained.
Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process Your Personal Data where more than one basis has been set out in the table below.
If you would like to opt out of any or all the processing activities mentioned below, please get in touch with Us using the information under the ‘Contacting Us’ section above. It may not be possible for opt out of a processing activity if we are required to keep it by law or if we hold it in connection with a contract with you.
Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest and conditions for processing Special Category DataTo register you as a new Customer user and maintain your registration(a) Registration Data(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:(a) Notifying you about changes to Our terms or Privacy Policy
(b) to Communicate with you: for instance, messages about the site and notifications about new content and activity on the site pertinent to you(a) Registration Data
(b) Technical Data(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
To contact you & to improve our services(a) including whether you’d be interested in participating in any research projects.(b) to ask you to partake / complete surveys: We may present a research survey to you and collect Personal Data from you if you agree to participate. We will inform you about why we wish to collect Your Personal Data and ask you for your consent before collecting it.(a) Member Content
(b) Survey(a) Necessary for Our legitimate interests (To improve our services or for research)
(b) Consent
To administer and protect our business and our Site:
including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Registration Data
(b) Technical Data(a) 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)
(b) Necessary to comply with a legal obligation
To use data analytics to improve Our site, products/services, marketing, customer relationships and experiences(a) Technical Data
(b) Customer User’s DataNecessary for our legitimate interests (to define types of services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy)
How we may disclose your Personal Data
We require all third parties we share Personal data with, to respect the security of your Personal Data and to treat it in accordance with the law.
Often we may need to share your Personal Data with other service providers in order to facilitate the running of the site. When this happens, we implement strict contractual agreements with such third parties. 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 disclose your Personal Data to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, but this will always be on a “need to know basis” and in compliance with Data Protection Legislation. 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 Policy.
Marketing
Business Customers
We may also use your Personal Data to send you and keep you updated with information by e-mail or message through the site about existing and new services from us and to send you information by e-mail or message through the site about related products or services of selected third parties that may be of interest to you.
If at any time you wish to no longer receive our marketing emails, or no longer consent to our use of the tracking pixel, an unsubscribe link is found at the bottom of every email where you can opt out.
You have the right at any time to stop Nourish Care from contacting you. If you no longer wish to be contacted for marketing purposes, please email marketing@nourishcare.co.uk.
Cookies
If you opt-in to receiving our emails, you are consenting to our use of a tracking pixel.
A tracking pixel operates in a similar way as cookies are used in web browsers. A tracking pixel is usually part of electronic mail marketing. We use the tracking pixel to gather data on how our email activity is received such as, but not limited to, device, IP address, open time, link activity and website activity if a user clicks through to our website from our marketing emails. We use this information to create a better site experience for you and our customers, help personalise emails and tailor the site experience for all who opt in to hear from us.
Our Sites use certain cookies, pixels, beacons, log files and other technologies. Please see our Cookie Policy to learn about the cookies we use and how to manage your preferences.
Privacy policies of other websites
Our site 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. Please note our Privacy Notice only applies to our Site, if you click on a link to an external website you should read their privacy statements. We do not accept any liability from the actions or omissions of any third-party websites which you may access.
Such third-party websites are not investigated, monitored or checked for accuracy, appropriateness, or completeness by us, and we are not responsible for any websites you may access via a recommendation or suggestion on the site. Including, linking to or permitting the use or installation of any third-party website or any third-party applications, software or content does not imply approval or endorsement by us. If you decide to leave the Site and access a third-party website or to use or install any third-party applications, software or content, you do so at your own risk.
Your right of access
You have the right to request copies of your Personal Data which we hold, this is known as a subject access request.
Your data protection rights
If you wish to make a data subject access request, please contact us by any of the means specified in the How to Contact Us section above.
Your right to rectification
This enables you to have any incomplete our inaccurate Personal Data we hold about you corrected, though we may need to verify the accuracy of the new Personal Data you provide to us. If you would like to do this, please contact us and let us know the information that is incorrect and the information you would like to be corrected.
Your right to restriction of processing
This enables you to ask us to suspend the processing of Your Personal Data in the following scenarios: (a) If you want us to establish the Personal Data’s accuracy; (b) Where our use of the data is unlawful but you do not want us to erase it; (c) 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; and (d) you have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate basis to use it.
Your right to object to processing
You may object to our 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 situation which makes you want to object to processing on this basis 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 basis to process your information which may override your right to object.
Your right to erasure
You request for us to erase all your Personal Data (also known as the “right to be forgotten”) in the following circumstances:
- It is no longer necessary for us to hold that Personal Data with respect to the purpose for which it was originally collected or processed;
- Consent is the lawful basis for Nourish Care holding your data and you withdraw your consent;
- You object to us holding and processing your Personal Data (and there is no overriding legitimate interest to allow us to continue doing so);
- We are processing your Personal Data for direct marketing purposes and you object to us processing for marking purposes;
- The Personal Data has been processed unlawfully; or
- The Personal data needs to be erased in order for us to comply with a particular legal obligation.
Erasure of your Personal Data may result in automatic closure of your Member Account and access to the log-in areas of Our Site.
Right to data portability
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. You can also request a copy of your information which we hold (this is known as a subject access request).
No Fee Usually Required
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 will notify you if this is the case.
Time Limit to Respond
We will 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 several requests. In this case, we will notify you and keep you updated.
Exceptions
It may not be possible for us to delete your Personal Data if we are required to keep it by law or if we hold it in connection with a contract with you. Similarly, access to your Personal Data may be refused if making the information available would reveal Personal Data about another person or if we are legally prevented from such disclosure.
Complaints
If you have any complaints about the way in which we have used your Personal Data and these have not been addressed by contacting us first, You can contact the relevant supervisory authority which in the United Kingdom is, the UK Information Commissioner’s Office. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
https://ico.org.uk/concerns/
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: +44(0)303 123 1113
