App Privacy Policy

Introduction

1. This Software App Privacy Policy, together with our Terms and Conditions and any other documents referred to in it, describes how First Thought Care Services Ltd, registered under company number 12767299 (“First Thought Care Services Ltd.”, “we”, “us”) will process any personal data we collect from you, or which you provide to us, in the course of using the Software App (the “Carer App”) services to which you are granted access (the “Services”).  
2. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
3. By accessing or using the Carer App and our Services, you acknowledge that you have read and understood this Privacy Policy, and agree and consent to the use, processing and transfer of your personal data by us, as described in this Privacy Policy.
4. For the purposes of the Data Protection Act 1998 (the “Act”) and EU Regulation 2016/679 – the General Data Protection Regulation in effect from 25 May 2018 (“GDPR”) we are a Data Controller. We are ICO registered with registration number ZA830999.

Scope of our services

1. We operate a platform that allows social care providers to manage the care of their clients. The Carer App enables the care staff of social care providers (“Users”) to access and add to the care and personal records of individuals that they care for (“Service Users”) on mobile devices.
2. Through the Software website, service managers or those deemed responsible enough to have administrator access (“Managers”) can manage access rights to the System and the profiles of Users and Service Users.

The information we collect

1. When you access the Carer App and/or use our Services, there are a number of ways in which you provide information and other data to us. You may be asked to provide us with the following personal information:
1. Full name
2. Address
3. Photos
4. Date of birth
5. Medical history
6. Other care documents and information.
2. Users may be required to input information for their Service Users, this may include providing detailed information on their medical history.
3. By accessing the Carer App, you consent to us processing and collecting this data, on the terms and for the reasons which are explained below.

How your information is used

1. As is true of most apps, it will be possible to gather information about your computer or device such as your IP address, browser type, referring/exit pages, and operating system. This information may be used to:
1. Create your personal First Thought Care Services profile.
2. Enable communication between all users.
3. Enhance user experience and improve our website/Carer App.
4. Drive future product development in line with customer platform and technology use.
5. Send you push notifications when you are using the website (if you do not wish to receive these notifications, you can contact us at jack.cook@ftcareservices.com to request no further notifications).
6. Send out a newsletter, service alerts or marketing communications.
7. Respond to your questions and concerns.
2. Certain features of the Carer App (such as uploading or downloading content) may need to access information on your device in order to work. By using such functionality, you consent to First Thought Care Services accessing your device and information. If we can, we will ask you before the Carer App accesses your device or information. You may also manage how the Carer App accesses your device or information using privacy settings on your mobile device or by uninstalling the Carer App.

How to edit, delete or access your information

1. You have the right to ask for a copy of any personal information that we hold about you, to correct any inaccuracies and to update any out-of-date information. You can also ask us not to send you direct marketing communications. However, please note that we may continue to send you service-related, non-marketing communications.
2. If you wish to exercise any of these rights or wish to object to our use of your personal information, please write to us at jack.cook@ftcareservices.com

Sharing your information

1. Except as described below, we will not share your information with any third parties.
2. We may disclose the information you provide us:
1. To our third-party APIs, including but not limited to Intercom and Google Analytics.
2. To any of our group companies (which means our subsidiaries, and our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
3. To protect the rights, property, or safety of ourselves or others, as required by law under any Carer App regulation. This may include disclosing information to other companies and organisations in connection with fraud protection and credit risk reduction.
4. To protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, when we believe in good faith that disclosure is necessary.
5. If First Thought Care Services Ltd. is involved in a merger, acquisition, or sale of all or a portion of its assets, to any prospective seller or buyer of all (or part of) our business or assets. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
6. As part of a completely anonymised data set to research bodies or other organisations to perform analysis.
7. To any other third party with your prior consent to do so.
3. We will never pass your information or your Service Users’ information to a third party for them to use in their own direct marketing without your express consent.
4. Please note that if you click on or follow any links from the Carer App to external websites, this Privacy Policy will no longer apply to you. Please check the privacy policies of any such external website or app before submitting any personal data, as we cannot accept any responsibility or liability in relation to them.

Security, data retention and storage

1. The security of your personal information is important to us. All information you provide to us is stored using Amazon Web Services and hosted within the European Economic Area (“EEA”).
2. Any payment transactions and databases will be encrypted using SSL technology and AES-256 respectively.
3. We will retain your information for as long needed to provide you services via the Carer App. Once your account has been deleted, we will only retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
4. If you wish to cancel your account or request that we no longer hold your personal information, contact us at jack.cook@ftcareservices.com

International transfers

1. Information we collect may be transferred to, stored and/or processed in any country or territory where one or more of our partners or third-party service providers (for example, our hosting company) are located or maintain facilities, including destinations outside the EEA.
2. While other territories may not have the same standards of data protection as those within your home country, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
3. By submitting your personal data, you agree to this.

Contacting you

1. We may contact you from time to time about First Thought Care Services, including marketing messages relating to First Thought Care Services. We will do this electronically, for example by email, text, notifications or other messages on your Carer App, mobile device, telephone or by post.
2. We may contact you with information about our products and services (and those of specially selected parties that may be of interest to you) in line with your marketing contact preferences provided to us either through the Carer App or by emailing us. All such communications will come from First Thought Care Services Ltd.
3. You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at the email below or by following any instructions we may include in the messages we send to you

Use of location data

1. The Carer App may make use of location data sent from your mobile device. You can turn off this functionality at any time by switching off the location services settings for First Thought Care Services on your mobile device.
2. If you use these services, you consent to the transmission, collection, maintenance, processing and use of your location data and queries to provide and improve location-based and road traffic-based products and services, by us, our partners and licensees. You may withdraw this consent at any time by turning off the location services setting on your mobile device.

Syncing with other apps

1. The Carer App enables a User to sync their App with their camera feature on their device. Photos will be stored in the App and not on Users’ devices. We may ask permission to sync with your camera on your device to:
1. Enable uploading your photos into the care record of the Service Users.
2. Scan barcodes of medications, stickers or other products.
2. By using the Carer App, you accept that:
1. Other Users, Managers and Administrators from your organisation will have access to your uploaded photos.
2. If you sync your camera with the Carer App, you consent to us accessing your photos and storing the photos solely for the purposes described above. We will not collect or store any names, emails, addresses or other contact information from your device. If you do not want to use this feature or do not want your photos to be uploaded or accessed in any way you may unsubscribe from our Services.

Your rights

1. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting us at jack.cook@ftcareservices.com
2. The Act and the GDPR give you the right to access information held about you. Your right of access can be exercised in accordance with the Act and the GDPR.
3. You also have the right to:
1. Access the information that we hold about you.
2. Be informed of what data we hold and the purpose for processing the data as a whole or in parts.
3. Request data to erased/be forgotten by ourselves and our affiliates (this is not an absolute right).
4. Rectify information that we hold about you that is incorrect or incomplete by ourselves and affiliates.
5. Restrict processing of the information we hold about you (so that inaccuracies may be corrected etc.).
6. Object to the processing of your data.
7. Obtain and reuse the information that we hold about you.
4. You may revoke your consent at any time by emailing us  jack.cook@ftcareservices.com.

Accessibility and changes to this Privacy Policy

1. We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Carer App prior to the change becoming effective. We encourage you to periodically review this section and our website for the latest information on our privacy practices.
2. This Privacy Policy and all changes made hereto as described in the previous paragraph remain effective unless and until we inform you otherwise via a notification through the Carer App, through email (sent to the e-mail address specified in your account) or by means of a notice on our website prior to the expiration of this Privacy Policy.
3. The Carer App is currently available on the Apple and Google Play App Stores. The requirements of iOS and Android devices may vary (and for any additional operating systems we decide to extend the availability of the Carer App to) and may change, and you will need to download any necessary updates if you want to keep using the Carer App. We do not promise to always update the Carer App so that it is relevant to you and/or works with the iOS and Android version that you have installed on your device.

Contact

1. If you have any questions about our Privacy Policy and the data we hold on you, or you would like to exercise your data protection rights, you can contact us at  jack.cook@ftcareservices.com.