Throughout this Privacy Policy, ‘we’ or ‘Tended’ means Tended Limited of Boole Technology Centre, Beevor Street, Lincoln, Lincolnshire, England, LN6 7DJ. We are a provider of wearable safety devices, known as the Tended Protect, together with associated services. This policy explains how Tended uses your personal data, whether you’re shopping on Tended.co.uk, using a Tended Protect or are a person who is an emergency contact in case of any incident recognised by a Tended Protect. We will also use cookies to collect personal information about you when you use our website. It’s important that you read this privacy policy so that you know what we do with the information we process about you. We’ll be clear and open with you about why and how we collect and process your personal information and how we use it.

If you are using our website:If you are using our website, requesting information or purchasing from our website, we or our payment provider may collect, use, store and transfer the following information about you:

• Identity information, including your first and last name and title;
• Contact information, including your billing address, delivery address, email address and telephone numbers;
• Financial information, including your bank account, payment card or other payment method details e.g. Paypal, details;
• Transaction information, including details about payment to and from you;
• Technical information, including your internet protocol (IP) address, login data, browser type and version, operating system and platform, and other technology on the devices you use to access this website;
• Usage information, including how you use our website, products and services;
• Marketing and communications information, including your preferences in receiving marketing from us and your communications preferences; and

If you are an emergency contact:

The Tended service requires that an owner or user of a Tended Protect provide emergency contacts who will be notified if the Tended Protect device registers a potential accident or emergency and the owner of the Tended Protect does not respond to the notification from the Tended Protect to check if the wearer is OK or if the owner or user triggers an alert.

If you are an emergency contact we may collect, use, store and transfer the following information about you:

• Your contact details, specifically your name and telephone number; and

If you are an emergency contact and no longer wish for Tended to process your personal information as explained in this Privacy Policy, you should let us know and will delete your personal information from our records.

If you are a Tended Protect owner and/or user:

If you are an owner and/or user of a Tended Protect we may collect, use, store and transfer the following information about you:

• Identity information, including your first and last name, date of birth and gender;
• Contact information, including your email address;
• Technical information, including your internet protocol (IP) address, login data, browser type and version, operating system and platform, and other technology on the devices you use to access the application;
• Profile information, including password
• Usage information, including how you use our app, products and services;
• Marketing and communications information, including your preferences in receiving marketing from us and your communications preferences;
• Device information, including the type of mobile device you use, such as the model of your phone, the version of the operating system and the version of the app that has been installed, a unique device identifier
• Marketing and communicationDevice information, including the type of mobile device you use, such as the model of your phone, the version of the operating system and the version of the app that has been installed, a unique device identifiers information, including your preferences in receiving marketing from us and your communications preferences; and
• Movement information, this is captured by the Tended Protect using its accelerometers and transferred to the Tended App on your phone for analysis to identify events that may require an alert to be triggered. This movement information is uploaded to Tended. The fact that you have fallen or have not moved and have not responded or have triggered an alarm will be uploaded to Tended and then sent to your emergency contact. Movement data may be sampled and sent to Tended as part of general data gathering to improve fall detection and other adverse events. Such data may retain an identifier to associate it with a specific device but such identifier will only be used to remove such data if that is required.
• Contact information, including accessing your contacts in your mobile device to simplify the set up process for your emergency contacts in the Tended mobile application;
• Microphone and speaker information, this is only used when an alert is triggered and if you allows us access to your microphone when setting up. This enables your emergency contact to talk to you through our app. This is only activated for the duration of the emergency. We do not record voice interactions through our app;
• Location information, including GPS technology to determine your current location. Our location-enabled services require your personal data for the feature to work. To use our Service you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings but the Tended Protect Service will then not function to advise your emergency contacts where you are in the event of an emergency; and
• Health information, including Pre-existing medical conditions, medications, height, weight, allergies and blood type. None of this information is required to create an account.
• Activity information, that you identify as such and movement data captured to identity a fall or lack of activity. This is required for the functionality of the services for which you are or have acquired the tended Protect.
  
• Profile photo, we may request access to your camera to take a profile photo, or we can request access to select one from your photo gallery or social media account. A profile photo is not required to use the Tended Protect.

When you use our services and the Tended Protect app, some of the information we process may be ‘sensitive’ information (also known as special category personal data). This may include information about your medical history, including any major incidents illnesses, your general health, in particular the health information you enter as part of your profile and the movement data processed by the Tended Protect device. We will also process the fact that an alarm has been triggered either automatically or intentionally. We understand the sensitivity of this information and will only use it to provide you with the Tended services.

We will collect and process your personal information about you:

If you are using our website:

If you are using our website, you may give us your personal information through direct interactions, by filling in forms online or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

• apply for our products or services;
• create an account on our website;
• request marketing to be sent to you;
• give us feedback or contact us; or
• Technical information such as IP addresses may be collected as part of normal use of our website

If you are an emergency contact:

If you are an emergency contact, you may give us your personal information through direct interactions, by filling in forms online or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you agree to be an emergency contact for a Tended Protect owner, your details will be provided by the Tended Protect owner.

If you are a Tended Protect owner/user:

If you are Tended Protect owner/user, you may give us your personal information through direct interactions, by filling in forms online or by corresponding with us by post, phone, email or otherwise and from your use of the Tended Protect. This includes personal information you provide when you:

• fill in forms on the Tended Protect app and when requesting services;
• register to use the Tended Protection app, download or register an app;
• when you report a problem with an app or our services;
  
• request marketing to be sent to you;
• give us feedback or contact us; or
• share data via an app's social media functions.

Information we receive from other sources, including third parties and publicly available sources:

We will receive personal data about you from various third parties and public sources as set out below:

• Device information from the following parties:
• analytics providers such as Google based outside the EU;
• advertising networks such as Facebook based outside the EU; and
• search information providers such as Google based outside the EU.
• analytics providers such as Google based outside the EU;
• Contact, financial and transaction Data from providers of technical, payment and delivery services such as Shopify based outside the EU;
• Identity and contact information from publicly available sources such as Companies House and the electoral register based inside the EU; and.

Information we get from your employer:

If you’re using a Tended Protect device issued to you by your employer, your employer can create a profile for you using the Tended service and may put information in that profile. That profile will remain accessible to your employer and subject to their employment rules and privacy obligations. Tended will have access to that information in certain limited circumstances, e.g, your employer is unable to access such data, but access is highly restricted within Tended and the data is maintained in encrypted form. Such data may include some of the information detailed above for Tended Protect owner/users plus such information as is held by an employer such as next of kin. We will not use such data for any Tended purpose.

We will also have the personal information detailed above for Tended Protect owners/users.

We use your personal information for a number of different purposes. Some are essential for us to provide the services you use or to fulfil our legal obligations, some help us run our business efficiently and effectively and some enable us to provide you with more relevant and personalised offers and information. In all cases we must have a reason and a legal ground for processing your personal information. The legal grounds we rely on are explained below.

We only rely on legitimate interests where we have balanced the interest being pursued against your interests, rights and freedoms and have concluded that the processing is not unwarranted. If you would like to see a copy of our legitimate interests assessment, please contact us using the details below.

The Tended Protect Service relies upon automated decision making for deciding whether an event warrants triggering an alert. The Tended Protect device will always query whether you are OK before triggering an alert except when you specifically trigger a voluntary alert. The automated decision making is not used by Tended to profile you beyond enhancing the accuracy of identifying triggering events for you and people similar to you as regards their activities undertaken e.g. running, cycling, walking. We take your downloading and activation of the Tended App and use of the Tended Service as representing explicit consent to this automated decision making. If you withdraw such consent which you may do by contacting support@tended.co.uk you will not be able to use the Tended Services.

Please note that where you have given your consent for us to process your personal data, you have a right to withdraw your consent at any time by contacting support@tended.co.uk.. This right applies only to processing activities which are carried out on the basis of consent. If you withdraw your consent the Tended Protect Service will not be able to function so alerts cannot be created and sent to your emergency contacts. If you withdraw your consent to us using your information, we will delete all of your information from our systems and we will not use your information as part of our research. We will also be unable to provide the Tended Services and therefore to issue alerts in the case of identified emergencies or if you trigger an alert.

Where we process your ‘sensitive’ information, we do so on the basis of your explicit consent which is obtained when you download and activate our app.

We may anonymise and aggregate any of the personal information we hold. This means that it will not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our website, apps and products and developing new products and services.

We will not use your information for any other purposes unless we are required to do so by law.

We will send your identity, your location and your medical information (if added to your profile in the Tended app) to your emergency contacts if an alert is triggered.

We use third party suppliers to provide services to us, for example IT services to us. These suppliers may process your information on our behalf. Such suppliers include Twilio who will receive data to send texts or make calls in the case of an alert. Google in respect of Google analytics for website and advertising impact assessments, Amazon Web Services for data storage and processing.

We may share your personal information with third parties where required or permitted by law, if we believe we need to do so to exercise, defend or protect our rights, or to comply with legal proceedings.

Where you have a Tended Protect device as an employee and provided to you by your employer the Tended service may give your employer information about you. Such information will be under the control of your employer and will be subject to their data protection obligations and policies. Such information may include health data you have set up in the app, the fact that a triggering event has occurred and your location at that time. Your employer may also set up a “are you OK” request and trigger such a request which will request that you confirm that this information is sent to your employer.

If ownership of all or part of our business changes, or we undergo a reorganisation we may transfer your personal information to the new owner or successor company so we can continue to provide you with the Tended services.

The EEA comprises of all of the European Union countries and Iceland, Liechtenstein and Norway. Personal data can be transferred, processed and stored within these countries safely and securely as they offer an adequate level of protection to personal data in comparison to the UK.

We take your data very seriously, therefore we’ll always conduct a full review of all of our suppliers’ processes and procedures including storage solutions for our data. In order to ensure adequacy when we or any third party sends your data outside of the EEA, we always require that appropriate safeguards are present to protect your personal information when it is processed.

On an emergency alert being sent to your emergency contacts a link to your personal data will be sent to such emergency contacts irrespective of where they are at that time. In doing so, such personal information may pass through or end up outside the EEA and in a country which does not have the same level of protection for personal data.

If you are outside the EEA your movement data will be transferred to Tended via networks located in countries that may not have the same level of protection for personal data as is required in the EEA.

We hold your personal information for as long as necessary, depending on the purpose for which we use it. We only keep your personal information for as long as we have a legal reason to do so, which generally means as long as you remain a Tended customer or as required to meet our legal obligations, resolve disputes or enforce our agreements. We will always store your data securely and won’t use it for any other purpose. Personal information will normally be deleted within two years of the end of our contract with you unless we have reason to consider that it may need to be retained for longer in respect of disputes or claims.

Where you have been supplied with a Tended Protect device by an employer as an employee your employer may retain your personal data with Tended in accordance with their data retention policies.

By law, you have a number of rights when it comes to your information, which we summarise below.

To exercise any of these rights, or to ask any questions about your rights, please contact us. We’ll respond as soon as we can and in any event within one month from when we receive your request. We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• Excessive or unfounded requests; or
• Further copies of the same information.

We’ll make it easy for you to update or change your personal details or marketing permissions. Please help us to help you by letting us know if your contact details change, or if you spot any errors in the information we hold about you by using the contact us page.

You have the right to be informed about how Tended processes and uses your personal information. This is why we’re providing you with the information in this Privacy Policy.

Your right of access

You have the right to obtain a copy of the information that Tended holds about you, including personal details, correspondence, consent information, complaints and queries. If you would like a copy of the information Tended holds about you or have any queries about the way Tended handles your personal information, please contact us.

Your right to rectification

You have the right to ask us to update the personal information we hold about you, or correct any personal information that you think is incorrect or incomplete.

Your right to move your data (the data portability)

Under certain circumstances, you can request that Tended provides you with a copy of your personal information on a standard commonly used and machine readable format and/or transmit your data to another service provider. This is not an automatic right, and depends on the reason Tended processes the data and on what Tended are able to do technically. Please contact us to request a data move.

Your right to restrict processing

You have the right to request that Tended stops certain data processing activities that involve processing your personal data, this can be processes such as the operation of the Tended service or processing your name and address on your Tended.co.uk account to deliver goods to you, among other examples. This isn’t an automatic right, what Tended are able to do will depend on the processing undertaken. Please contact us to request that we cease processing your data.

Your right to object

Under certain circumstances, you have the right to object to our processing of your personal data.

Your right to request deletion (the right to be forgotten)

You have the right to request that Tended deletes your personal data it holds. This isn’t an automatic right, what Tended are able to delete will depend on the processing undertaken. Please contact us to request your personal data be deleted.

Processing data about children

Tended does not recommend that a child be given the Tended Protect device and be given use of the Tended service via the Tended app. If Tended determines that the Tended Protect is being used by a person it reasonably believes is a child or minor under the age of 16, we will notify the purchaser of that device and also send a message via the Tended app that we will close that account within 1 day. Where a Tended Protect device is being used by a child or minor under 16 unknown to Tended the personal data will be processed and stored as if the child or minor was an adult.

If you have any questions on the processing of your information, would like to exercise any of your rights, are unhappy with how we’ve handled your information or have any other questions relating to this policy please contact support@tended.co.uk.

Alternatively, you may also write to us at:

Boole Technology Centre
Beevor Street
Lincoln
Lincolnshire
England
LN6 7DJ

If you are not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you have the right to make a complaint to the relevant data protection regulator. In the UK, this is via the Information Commissioner’s Office (ICO)

Information Commissioner’s Office
Wycliffe house, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113
www.ico.org‍

This Privacy Policy was updated in August 29th 2019. We may update it from time to time so we recommend that you check back here occasionally. If we make changes we think may affect you significantly, particularly if they could have an impact on the choices you have made about marketing, we’ll provide you with a prominent notice by the most appropriate medium so you know about the changes before they happen.