UK Office: +44 330 133 1195
info@tended.co.uk
Privacy Policy
  1. Who are we?
  2. Purposes of this Privacy Policy
  3. What personal data do we process?
  4. How is your personal information collected?
  5. How we use your personal information
  6. Who we share your personal information with
  7. How do we share your data outside the EEA?
  8. How do we safeguard your personal data?
  9. How long do we keep your personal information?
  10. Staying in control of your information: Your rights
  11. How you can contact us
  12. Changes to this Privacy Policy
1. Who are we?

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, together with associated software and services.

2. Purposes of this Privacy Policy

This policy aims to give you information on how we collect and process your personal data through your use of our devices, software, services and website, including any data that you may provide when you contact us, sign up to use our software or services or use our devices.

We will also use cookies to collect personal data about you when you use our website. Click here for our Cookies Policy and the full list of cookies we use on our website.

It’s important that you read this Privacy Policy so that you know what we do with the personal data we process about you. We’ll be clear and open with you about why and how we collect and process your personal data and how we use it.

3. What personal data do we process?

The type of personal data we process depends on how we interact with you.

If you are using our website:

If you are using our website or requesting information, we may collect, use, store and transfer the following personal data:

● Identity information, including your first and last name and title;
● Contact information, including address, email address and telephone numbers; 

● Technical information, including your internet protocol (IP) address, login data, browser type and version, operating system and platform, time zone setting and location, and platform, and other technology on the devices you use to access our website, software and services; 

● Usage information, including how you use our website, devices, software and services; and
● Marketing and communications information, including your preferences in receiving marketing from us and your communications preferences.

For an emergency contact: 


Some of the services that we provide require that an owner or user of our device(s) provides emergency contacts who will be notified in the event that the device registers a potential accident or emergency. In such circumstances, the owner or user of the device will be sent a notification which they will be prompted to respond to. If no response is detected from the device, an alert is triggered and sent to the emergency contact(s).


If you are an emergency contact, we will collect, use, store and transfer the following personal data: 


● Your contact details, specifically your name and telephone number. If you are an emergency contact and no longer wish for Tended to process your personal data, as explained in this Privacy Policy, you should let us know and will delete your personal data from our records.

If you are a device owner and/or user:

If you are an owner and/or user of our devices we may collect, use, store and transfer the following information about you either through the device itself or through a connected software app:

● Identity information, including your first name, last name, title date of birth and gender; 

● Contact information, including address, email address and telephone numbers; 


● Technical information, including your internet protocol (IP) address, login data, browser type and version, operating system and platform, time zone setting and location, and platform, and other technology on the devices you use to access our website, software and services; 

● Profile information, including login name and password; 

● Usage information, including how you use our website, devices, software and services; and
● 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 

● Movement information, this is captured by the devices using its accelerometers and transferred to an application hosted on your phone for analysis to identify events that may require an alert to be triggered. This movement information is uploaded to our servers. The fact that you have fallen or have not moved and have not responded or have triggered an alarm will be uploaded to our servers and then sent to your emergency contact. Movement data may be sampled and sent to our servers 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. 

● Saved 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 allow 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 and geofencing to determine your current location. Some of our devices can determine your location relative to other devices and/or other objects and areas. Our location-enabled services require your personal data for the feature to work. To use our services, 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 device 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 identify 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 software, 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 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 services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.

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, or your employer, and you fail to provide that data when requested, we may not be able to perform our obligations under that contract (for example, to provide you with devices and/or services). In this case we may have to revoke your access rights to our software and services and require you to return any of our device(s) to us or your employer.

4. How is your personal information collected?

We use different methods to collect data from and about you depending on how we are interacting with 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:

● request a demonstration of our devices and/or software; 

● request marketing to be sent to you; 
sign up to our newsletter; or
● give us feedback or contact us.

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 an owner or user of one of our devices. Your details will be provided to us by the device owner or user.

If you are a device owner/user:

If you are a device owner/user, you may give us your personal data 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 device.

This includes personal information you provide when you:
● fill in forms on our software and apps and when requesting services; 

● register to use our software and apps, download or register an app; 

● when you report a problem with our software or apps 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.
● Contact, financial and transaction Data from providers of technical, payment and delivery services such as Shopify based outside the EU; and
● Identity and contact information from publicly available sources such as Companies House and the electoral register based inside the EU.  

Information we get from your employer: 
      

If your employer issues one of our devices to you, they can create a profile for you using our software and may put your personal data in that profile. That profile will remain accessible to your employer and subject to their employment rules and privacy obligations. We will have access to that personal data in certain limited circumstances, for example, 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 device 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 hold the personal data detailed above for device owners/users. 


4. How we use your personal information?

We use your personal information for a number of different purposes when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

● Where we need to perform a contract we are about to enter into or have entered into with you or your employer;
● 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 get your consent 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 when 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 personal data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table 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.


6. Who we share your personal information with?

We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above:

Your emergency contacts

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.

Our Suppliers

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.

Legal obligations

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.

Employers

Where you have one of our devices as an employee that was provided to you by your employer, the services 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 an “are you OK” request and trigger such a request which will request that you confirm that this information is sent to your employer.

Changes to our business

If ownership of all or part of our business changes, or we undergo a reorganisation we may transfer your personal data to the new owner or successor company so we can continue to provide you with the services. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

7. How do we share your data outside the EEA?

Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

For further details, see European Commission:

Adequacy of the protection of personal data in non-EU countries. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. The EEA comprises of all of the European Union countries and Iceland, Liechtenstein and Norway. 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. Our devices are only intended for use within the United Kingdom.

If you use our devices outside of 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.

8. How do we safeguard your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. How long do we keep your personal information?

We hold your personal information 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 we reasonably believe there is a prospect of litigation in respect of 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.

In some circumstances you can ask us to delete your personal data: see staying in control of your information: your rights (below) for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Staying in control of your information: Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as summarised below.

To exercise any of these rights, or to ask any questions about your rights, please Contact Us. We will respond as soon as we can, and usually within one month from when we receive your request.  Occasionally it could take us longer to respond than one month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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.


Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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 personal data we hold about you by using the Contact Us page. 


Your right to be informed

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


Your right to request access


You have the right to obtain a copy of the personal data that we hold about you, including personal details, correspondence, consent information, complaints and queries. If you would like a copy of the personal data we hold about you or have any queries about the way we process your personal data, please Contact Us.

Your right to request rectification

You have the right to ask us to update the personal data we hold about you, or correct any personal data that you think is incorrect or incomplete, though we may need to verify the accuracy of the new data you provide to us.

Your right to request erasure

You may ask us to erase your personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Your right to object to processing

Under circumstances, such as where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground 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 grounds to process your information which override your rights and freedoms.

Your right to request restriction of processing

You may ask us to suspend the processing of your personal data in the following scenarios:If you want us to establish the data’s accuracy.Where our use of the data is unlawful but you do not want us to erase it.Where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims.You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Your right to request transfer

Should you ask us to transfer your personal data to you or a third party, we will provide to you, or the third party, 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.

Your right to withdraw consent at any time

You may withdraw consent to us processing your personal data at any time by Contacting Us. However, this will not affect the lawfulness of any processing carried our 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.

Processing data about children

Tended does not recommend that a child be given access to our devices nor do we recommend that they be given access to our software. If we determine that our devices are being used by a person we reasonably believe 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 the associated user account within one day of such notification. Where one of our devices is being used by a child or minor under 16 unknown to us, their personal data will be processed and stored as if the child or minor was an adult.

11. How you can contact us?

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

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 personal data 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. The ICO’s website is www.ico.org.

12. Changes to this Privacy Policy

This Privacy Policy was updated on 31 August 2020. 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.