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Age Co Personal Alarms Privacy Policy

Age Co Personal Alarms Privacy Policy

The Age Co Personal Alarms service and website is provided by Taking Care (PPP Taking Care Limited). Taking Care is the trading name and brand of PPP Taking Care Limited and a subsidiary of AXA Health. To read Age Co's privacy policy, please click here.

PPP Taking Care Limited (“Taking Care”, “us”, “our” and “we”) is a provider of telecare products and monitoring and support services. We are part of the AXA Group of companies. We take your privacy seriously; we promise to take steps to protect it. This privacy policy tells you how we collect, store and use your personal information, as well as the rights that you have over it. We treat personal information in accordance with data protection laws.

Taking Care Privacy Principles
Definitions
Information we collect and how we collect it
How we use your information and the legal bases that we rely on
Sharing personal information
Processing outside the UK and the European Economic Area
Data Retention
Your rights
Contacting the Data Protection Office
Company information

1. Taking Care Privacy Principles

When we collect and use your personal information, we look after it properly and use it in accordance with our privacy principles:

Personal information you provide is processed fairly, lawfully and in a transparent manner.
Personal information you provide is collected for a specific purpose and is not processed in a way which is incompatible with the purpose for which we collected it.
Your personal information is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
Your personal information is kept accurate and where necessary kept up to date.
Your personal information is kept no longer than is necessary for the purposes for which it is processed.
We take appropriate steps to keep your personal information secure.
Your personal information is processed in accordance with your rights.
We will only transfer your personal information to another country or an international organisation outside the United Kingdom or outside the European Economic Area when we have taken steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards.
Taking Care does not sell your personal information and we also prohibit the selling of customer data by any company which provides a service to us.

2. Definitions

We’ll use these terms throughout this privacy policy, so that we can more easily describe how we treat personal information about the different groups of people with whom we interact.

Taking Care Services (our Services)
The telecare products and monitoring and support services that we provide.

Taking Care Customer (Customer)
The person who has paid for the service and assumes responsibility under the contract. The Customer is typically a Nominated Contact of the person using our products and services.

Taking Care User (User)
The end user of our social care products and services.

Nominated Contact
A person who lives locally to the Taking Care User, whom we will contact to provide assistance in case of an emergency or if otherwise required.

3. Information we collect and how we collect it

3a. Information about Taking Care Customers, Taking Care Users and Nominated Contacts

The personal information we collect in connection with our Services includes:

Taking Care Customers: name, email address, home address, telephone number, date of birth, time away from home (for instance on holiday), and bank/credit card details.

Nominated Contacts: names and contact information, as well as information about time away from home. Nominated Contacts are often also Taking Care Customers.

Taking Care Users: name, home address, email address, telephone number, date of birth, time away from home (for instance on holiday), information about Key Safes (as applicable) and information about houses and gardens so that we can assess the risk of falls (e.g. if there are stairs). We also collect sensitive personal information (known in Data Protection law as ‘Special Category Data’) such as information concerning physical and mental health, including conditions and medication. We collect NHS numbers.

If Users have chosen a ‘location-aware’ product, we collect GPS location and sudden, sharp movements as part of our fall detection service

If Users have chosen a ‘Smart Home Monitoring’ product, we collect information about movements around the home and entries and exits, to build up an understanding of daily routine and variances from it. Our Taking Care Sense proactive monitoring system also collects information about changes in temperature and humidity in homes.

If Users have chosen a Taking Care Prevent activity wearable device, we collect information about activity levels, sleep pattern and heart rate.

How we collect this information

We collect personal information directly from Taking Care Customers and/or Users in different ways, including:

during enquiries about, or purchase of, our Services on the phone, by email or on Live chat.
when you register for and log into our online services (e.g. mobile apps and web portals) and provide information to us in this way – for instance, you can provide more information to enable us to assess your risk of falling while in your property.
when using our Services, for instance if you call our Emergency Resolution teams for assistance
from your use of wearable and/or ‘location aware’ products, mobile devices, and Smart Home Monitoring products if you have subscribed to them
through cookies which monitor how users interact with our websites. For more information, see our Cookie policy.

We also collect information about Taking Care Customers and Taking Care Users, including sensitive personal information, in other ways:

from Taking Care Customers about Taking Care Users
from Taking Care Customers or Taking Care Users, about Nominated Contacts (you should have your Nominated Contact’s permission to share their contact details with us)

We may also collect personal information about Customers and Users from other organisations, for example:

Business partners (e.g. local authorities, charities, corporates)
Providers of technical, payment and delivery services
Websites where you may leave reviews abouts us, e.g. Trustpilot
Advertising networks
Analytics providers
Search information providers
Credit reference agencies
Aggregators and data brokers

4. How we use your information and the legal bases that we rely on

We process personal information for different reasons, which we describe below. Under data protection law we can only process personal information when we have a legal basis to do so; these legal bases are set out in data protection law.

When the personal information is classed as sensitive personal information (for example information relating to health which is also known as ‘Special Category Personal Data’) we must additionally have a legal condition to process it. The legal conditions which we rely on are also set out in data protection law.

4a. To provide PPP Taking Care Services

When providing our Services, we use information about Taking Care Customers and/or Taking Care Users:

To contact Customers and/or Users about the Service (e.g. for verification or billing purposes, or to enable us to recover any money owed to us)
To provide the agreed Service, for example:
1. Providing the Emergency Resolution Service in response to emergency alarm calls, including liaising with Nominated Contacts, doctors/healthcare providers, emergency services, other response service providers (including organisations coordinating volunteers and charities) and social services
2. Discussing health concerns, medication and treatment, and guidance and reassurance as part of our Medical Helpline Service
3. providing our GPS and motion sensor enabled services

Legal basis
When we process your personal information to provide our Services, the principal legal basis that we rely on is that the processing is necessary to provide the products and services under the contract.

The legal condition that we rely on when our processing includes sensitive information, is that it is necessary for health or social care purposes.

We may also rely on other the legal bases to process personal information (including sharing it with emergency services): it is necessary to process it to protect a User’s vital interests; or it is necessary to process it to safeguard their wellbeing (for instance, advising Nominated Contacts or care providers that we are withdrawing our Services).

4b. Optimising online channels

We use the information collected through use of our website to administer, maintain, and improve it. For instance, information about how people interact with our website helps us to make it easier to find information and services. Login information allows us to authenticate the identity of people accessing our apps and portals and keep information secure. Some personal data may also be used to understand and improve the effectiveness and relevance of the advertising we present to individuals online.

Legal basis to process personal information
The legal basis that we rely on to process your personal information for these purposes is that it is in our legitimate business interests to maintain, secure and optimise our online channels.

4c. Using your Information for Business Management Purposes

We use your personal information in order to carry out our business operations such as maintaining our accounting records, analysis of financial results, internal audit requirements and receiving professional advice (e.g. tax or legal advice). We also process it to secure and maintain effective operation of our systems.
Analysis of personal information helps us understand our business and monitor our performance.
We also provide aggregated, anonymous reports to corporate clients and partners about the groups of people who use our products and services, and how they interact with them. Individuals cannot be identified from this reporting.
We also use Customers and Users’ general feedback, and responses from satisfaction surveys, to help us understand our business and monitor our performance. Where possible, we will anonymise your information before processing it for these purposes.

Legal basis
The legal basis we rely on when processing your personal information for Business Management Purposes is that it is in our legitimate interests to understand, monitor and operate our internal operations. When this requires sensitive information, the legal conditions that we rely on, depending on the processing, is that it is necessary for statistical purposes, necessary for the purposes of health or social care, or because you have provided your consent.

4d. For quality, training and security purposes

We may record phone calls that you have with our customer services representatives and use some of these for quality monitoring and training purposes, and as a record of our conversation.

Legal basis
The legal bases that we rely on is that we have a legitimate business interest to process personal information for service improvements, and that we may need to do so to comply with our legal or regulatory obligations.

The additional legal condition that we rely on when calls include sensitive information, is that it is necessary for health or social care purposes.

4e. Telling you about products and services that may interest you

We collect your marketing preferences and your contact details so that we can send you information if you’re happy to receive it
We use demographic information about Customers and Users to understand more about the types of people who interact with us and purchase our products. This helps us to send relevant information to different audiences.
We may also use information about how you interact with our communications so we can gain insights into the performance of our campaigns. For instance, we use pixels and similar technologies so that we know whether an email we sent you was accessed; this type of insight means that we can provide you with more relevant content at optimum times.
If you’re a business customer or potential business customer, we’ll also process your business contact information and publicly available information about your business for these purposes.

For information on how to object to our use of your personal information for marketing purposes, please see Section 8.

Legal basis
Our legal basis for processing your personal information for marketing purposes is that it is in our legitimate interests or you have provided your consent.

4f. Anonymising your personal information

When required, we anonymise personal information so that individuals cannot be identified before we use it for management information and analysis of our products and services. Analysis of anonymous information provides us with insights about our business, and with opportunities to improve our products and services and the health and wellbeing of the people who use them. Analysis of anonymous information also allows us to demonstrate the value of the services we provide to our clients. The way that we anonymise personal information aligns with regulatory guidance and is achieved using different techniques, for example removing identifying data or overwriting it with randomised non-identifiable data.

Legal basis
Anonymisation still constitutes use of your personal information; we rely on the legal bases that we relied on when your data was originally collected.

4g. Recruitment

We collect and use personal information when you provide this to us as part of the recruitment process. This includes name, address (and evidence of it), contact details, national insurance number, professional information such as your job title, grade, employment history, education, and financial information relating to your salary and taxation.

Legal basis
The legal basis that we rely on is that the processing is necessary to contract with you, because it is in our legitimate interests or because we need to process the personal data to comply with a legal obligation.

5. Sharing Personal Information

We may disclose your personal information to third parties when we are under a duty to do so to comply with a legal obligation; this may include Coroners Court and Social Services.

We may also disclose personal information (including sensitive personal information) to the types of third parties listed below for the purposes described in this privacy policy:

Nominated Contacts, doctor or healthcare providers, social services and the emergency services as part of our Emergency Resolution Service. We may also provide personal information to other response service providers (including organisations coordinating volunteers and charities).
Taking Care Customers, Nominated Contacts, doctors or healthcare providers, social services and care providers, and organisations who purchase our Services on behalf of Users (e.g. charities and local authorities) as applicable, may be advised of a decision to remove our Services from particular Users.
Information about Users’ movements within their home, and leaving and returning from it, about changes in daily routines and normal patterns of behaviours, as well as extreme temperature changes, is shared with Nominated Contacts depending on Users’ subscriptions.
Our third-party services providers such as IT suppliers, communication providers, companies providing customer/user services (for example, personal alarm set-up and testing), auditors, lawyers, marketing agencies, research specialists, document management providers and contractors and their sub-contractors.

Before engaging third party service providers, we conduct risk assessments and put in place contractual arrangements and security mechanisms to protect your data in line with our data protection, confidentiality, and security standards.

6. Processing outside the UK and the European Economic Area

Some third-party recipients may be in countries outside the UK and the EEA. When we transfer your personal information outside the UK and the EEA we take steps to ensure that it is protected. Such steps may include placing the party we are transferring personal information to under contractual obligations to protect it to adequate standards.

7. Data Retention

We keep your personal information only for as long as reasonably necessary to fulfil the relevant purposes set out in this privacy policy and in order to comply with our legal and regulatory obligations. We typically keep information for 7 years either from the point we obtained the information or the end of our relationship with you. In some cases, such as if there is a dispute or legal action, we may keep it longer.

8. Your rights

The rights that you have over your personal information are described below. If you make a request, we’ll either do what you’ve asked, or explain why we can’t - usually for legal or regulatory reasons. When you make a request, we may ask you for information to confirm your identity and/or to enable us to carry out your request.

Please see Section 9 for our contact information.

The right to access your personal information
You are entitled to a copy of the personal information we hold about you and certain details about how we use it. There will not usually be a charge for dealing with these requests.

The right to rectification
We take steps to ensure that the personal information we hold about you is accurate and, to the extent necessary, complete. However, if you do not believe this is the case, you can ask us to update or amend it.

The right to erasure
You can ask us to erase your personal information, for example if we no longer need it for the purposes for which we collected it. However, we won’t always be able to comply with your request, usually for a legal or regulatory reason which we’ll advise you of at the time.

Right to restriction of processing
In certain circumstances, you can ask us to suspend using your personal information for a period. For example, if you think that the personal information we hold about you is inaccurate, you can ask us to stop using it while we verify its accuracy; or if you need us to retain your personal information beyond our retention periods, you can ask us not to delete it.

Right to data portability
In certain circumstances, you have the right to the personal information that you have provided to us in a machine-readable format. You can also ask us to provide this directly to a third party. Once transferred, the other party will be responsible for looking after your personal information.

The right to object
You can ask us to stop sending you marketing messages and to stop using your personal information for marketing purposes (e.g. profiling) at any time (see Section 9 for contact information). You can also follow the unsubscribe instructions in our emails to stop receiving marketing by email. We will continue to send you service related (non-marketing) communications.

You can also ask us to stop processing all or some of your personal information when we’re doing this for other purposes. Depending on the purpose and our legal basis for processing, we may not always be able to fulfil your request.

The right to withdraw consent
In some circumstances, we may ask for your consent to process your personal information, for instance if we want to use it for new purposes which we haven’t already told you about. You have the right to withdraw it at any time.

The right to lodge a complaint
You have the right to complain to the Information Commissioner’s Office (ICO) if you consider that we have not complied with data protection law. The ICO will usually expect you to have given us the opportunity to resolve your complaint before interceding, so please do bring any concerns to us in the first instance (see Section 9). More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/.

9. Contacting the Data Protection Office

If you’d like to make a rights request, or for any other data protection query or complaint, please contact: dataprotection@ppptakingcare.co.uk

The Data Protection Officer, PPP Taking Care Limited, Linhay House, Linhay Business Park, Eastern Road, Ashburton TQ13 7UP

10. Company Information

Registered Address: 20 Gracechurch Street, London, EC3V 0BG.

ICO Registration Number: Z7105141

Chichester Careline: Chichester Careline is a PPP Taking Care brand which provides telecare by a 24-hour staffed Alarm Receiving Centre (ARC). Chichester Careline is provided by PPP Taking Care.

^{Last updated 02/10/2024}