Privacy Policy

Amelio Tech Ltd, a company registered in England and Wales, with company number 15214053 (we, us or our), understands that protecting your personal data is important. This Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our website and care management application (Services) or when otherwise interacting with you.

It is important that you read this Privacy Policy together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.

The information we collect

Personal data: is information that relates to an identified or identifiable individual. We may collect, use, store and disclose different kinds of personal data about you which we have listed below:

• Identity Data including first name, last name and date of birth.
• Contact Data including billing address, email address and telephone numbers.
• Financial Data including bank account and payment card details.
• Transaction Data including details about payments from you to us and other details of products and services you have purchased from us.
• Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
• Profile Data including your username and password for our Services, support requests you have made, content you post, send, receive and share through our platform, feedback and survey responses.
• Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.
• Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
• Special Categories of Personal Data is a special category of personal data that includes details about your 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 actively request special categories of data about you, nor do we collect any information about criminal convictions and offences. If at any time we need to collect special categories of data about you, we will only collect it and use it as required or authorised by law.

How we collect personal data

We collect personal data in a variety of ways, including:

• Directly:We collect personal data which you directly provide to us, including when you log into our application, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
• Indirectly: We may collect personal data which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
• From third parties:We collect personal data from third parties, such as from your employer where they invite you to access our Services and details of your use of our website from our analytics and cookie providers. See the “Cookies” section below for more detail on the use of cookies.

End User Data

Where your personal data is input into our Services, or where our Services are made available to you through a third party (e.g. your employer or your healthcare provider), that business is the ‘controller’ of any personal data input into the Services (End User Data), and we act as a ‘processor’ to process End User Data on behalf of the controller. The controller is responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining your consent prior to transferring the End User Data to us to process on their behalf, and therefore End User Data is not covered by this Privacy Policy. You should view the controller’s privacy policy and/or contact the controller to understand their privacy practices in relation to your End User Data.

Purposes and legal bases for processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. We have set out below 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. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

• To enable you to access and use our applications and provide our Services to you. Identity Data, Contact Data, Transaction Data — Performance of a contract with you.
• To contact and communicate with you about our Servicesincluding in response to any support requests you lodge with us or other enquiries you make with us. Identity Data, Contact Data, Profile Data — Performance of a contract with you.
• To contact and communicate with you about any enquiries you make with us via our website. Identity Data, Contact Data — Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.
• For internal record keeping, administrative, invoicing and billing purposes. Identity Data, Contact Data, Financial Data, Transaction Data — Performance of a contract with you; to comply with a legal obligation; legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms and conditions and any other administrative points.
• For analytics, market research and business development,including to operate and improve our Services, associated applications and associated social media platforms. Profile Data, Technical and Usage Data — Legitimate interests: to keep our website updated and relevant, to develop our business, improve our Services and to inform our marketing strategy.
• If you have applied to work with us; to consider your application. Identity Data, Contact Data, Professional Data — Legitimate interests: to consider your employment application.
• To comply with our legal obligations or if otherwise required or authorised by law. All relevant Personal Data — To comply with a legal obligation.

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

Our disclosures of personal data to third parties

We may disclose personal data to:

• our employees, contractors and/or related entities;
• IT service providers, data storage, web-hosting and server providers such as Oracle, Workday and Microsoft Azure;
• professional advisors, bankers, auditors, our insurers and insurance brokers;
• our existing or potential agents or business partners;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
• any other third parties as required or permitted by law, such as where we receive a summons.

Overseas transfers

Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom. The level of data protection in countries outside of the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Privacy Policy. This includes:

• only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or
• including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

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.

Your rights and controlling your personal data

Your choice: Please read this Privacy Policy carefully. If you provide personal data to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Privacy Policy. You do not have to provide personal data to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties:If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.

Access, correction, processing and portability:You may request details of the personal data that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal data to a third party and, in some circumstances, to have personal data relating to you transferred to you or another organisation.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complaints

If you have concerns about how we handle your information

If you’re unhappy with how we’ve used your personal data, please get in touch with us first using the contact details at the end of this policy. When you contact us:

• Give us full details about your complaint
• We’ll investigate your concerns promptly
• We’ll respond to you in writing explaining what we found and what we’ll do to address your complaint

Your right to complain to the regulator

You can also make a complaint directly to the Information Commissioner’s Office (ICO), the UK’s data protection regulator, at any time.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

You don’t have to contact us first before going to the ICO, but we’d appreciate the opportunity to try to resolve your concerns directly with you.

Storage and security

We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We use cookies and similar tracking technologies on our website to enhance your browsing experience and improve our services.

What are cookies?

Cookies are small text files that are stored on your device when you visit our website. They help us remember your preferences and understand how you use our site.

Types of cookies we use

• Essential cookies: Necessary for the website to function properly
• Performance cookies: Help us understand how visitors interact with our website
• Functionality cookies: Remember your preferences and settings
• Marketing cookies: Used to deliver relevant advertisements and track campaign effectiveness

Cookie consent

When you first visit our website, you will see a cookie notice explaining our use of cookies. You can choose which types of cookies to accept through our cookie preference centre. You’ll find more information about the cookies we use in our cookie pop-up.

Managing your preferences

You can change your cookie preferences at any time by:

• Using our cookie preference centre on the website
• Adjusting your browser settings to refuse or delete cookies
• Visiting our cookie policy for detailed information about specific cookies

Please note that disabling certain cookies may affect the functionality of our website and your user experience.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal data which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Personal data from social network accounts

If you connect your account with us to a social network account, such as Google, we will collect your personal data from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.

The personal data that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or followers and any other personal data you choose to share.

We use the personal data we receive from the social network to create a profile for you on our application and provide our Services to you.

If you agree, we may also use your personal data to give you updates on the social network which might interest you. We will not post to your social network without your permission.

Artificial Intelligence (AI) Technologies

Overview

We may use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

• Conduct analysis and data processing
• Generate and modify content and coding
• Improve and optimise our services and operations
• Automate routine tasks and communications
• Personalise your experience with our services
• Support quality assurance processes
• Assist with customer support and queries

Data protection and security

When we work with third-party AI providers, we ensure they handle your personal data in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal data, and you maintain all the rights outlined in this privacy policy. When using AI with your personal data, we commit to:

Transparency and control

• We’ll inform you when AI is used to make decisions that may significantly affect you
• We maintain human oversight and review of significant AI-generated decisions
• Our staff are trained to understand AI limitations and verify outputs before relying on them
• We implement processes to verify the accuracy of AI-generated outputs

Security

• We use appropriate technical and organisational measures to maintain the security and integrity of your personal data
• We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

• We regularly assess and document risks associated with using AI to process personal data
• We implement appropriate measures to address these risks
• We continuously monitor AI performance and regularly review their impact

Use of geo-localisation data

We collect your precise or approximate location via our mobile application for the following purposes:

• service optimization;
• analytics and business intelligence;
• user support;
• feature development;
• for security and safety;
• to prevent and detect fraud; and
• as permitted by law.

We collect this information when our website or application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you.

Amendments

We may change this Privacy Notice from time to time. We will notify you if we make a significant change to this Privacy Notice, by contacting you through the contact details you have provided to us and by publishing an updated version on our website. For any questions or notices, please contact our data protection officer (DPO) at:

Amelio Tech Ltd, a company registered in England and Wales, with company number 15214053.

Data Protection Officer or Data Privacy Manager: matt.deacon-smith@amelio.tech