1. Introduction

1.1. Important information and who we are

Welcome to Enrich Digital Technologies Limited's Privacy and Data Protection Policy (“Privacy Policy”).

EnrichMyCare, software as a service (SaaS), herein after, services are provided by Enrich Digital Technologies Ltd ("we", "us", "our", "EnrichMyCare"), a company registered in England & Wales with company number 10203894 with registered offices at 1 Mackworth Avenue Derby DE23 3WB.

At EnrichMyCare, we care deeply about privacy. We are committed to protecting and respecting your privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal and sensitive information and how we comply with the law and guidelines of the UK's Data Protection Act (2018) and the EU General Data Protection Regulation (“GDPR”). We are a Data controller under UK law. This means we are responsible for determining the purposes for which and the manner in which the personal information provided to us is processed. This policy explains how we collect, process and keep your data safe when you visit or use our website ("https://enrichmycare.com " or the site) or our web platform ("https://web.enrichmycare.com ", "https://records.enrichmycare.com " or the platform) or our mobile application (the "Apps" downloaded from iOS and android app and play stores respectively). We'll refer to the Site, the Platform, the Apps, and our other services as the "Services". The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data. This policy does not apply to the practices of third parties who may also collect or receive data in connection with your use of the Services. Please note that we interact with other third parties (including GPs, healthcare providers and NHS central services). In some cases we are simply processing your personal information on their behalf. Such third parties may also be data controllers in their own right and have their own privacy policies.

The individuals from which we may gather and use data can include Users who are parents/carers of children and young people with disabilities, Professionals who provide health, social care, education and support services, managers and Joint Commissioners of health and local authorities, business contacts, employees and/or care givers of our Users, and any other people that the Users has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members, contractors and vendors and all Personal Data processed at any time by us.

Please use the Glossary at the bottom of this policy to understand the meaning of some of the terms used in this Privacy Policy.

1.2. Who is Your Data Controller and Data Protection Officer

Enrich Digital Technologies Limited is your Data Controller and responsible for your Personal Data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the Data Protection Officer at [email protected] or postal address 1 Mackworth Avenue, Littleover, Derby, DE23 3WB

You have the right to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3. Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging the responsibilities of the Data Controller, we have Processors who deal with your data on behalf of the Data Controller. Therefore, the responsibilities described below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Processor has the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the UK-GDPR and EU-GDPR (see 2.2 below for more information on those bases)

• Ensure that persons authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality

• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal and sensitive Data

• Obtain the prior specific or general written authorisation of the Controller before engaging another Processor

• Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the UK-GDPR and EU-GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller

• Maintain a record of all categories of processing activities carried out on behalf of a Controller

• Cooperate, on request, with the supervisory authority in the performance of its tasks

• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process them except on instructions from the Controller

• Notify the Controller without undue delay after becoming aware of a Personal Data Breach
Designate a data protection officer where required by the UK-GDPR and EU-GDPR, publish their details and communicate them to the supervisory authority

• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain his or her expert knowledge

2. Legal basis for data collection

2.1. What Personal information do we collect and how do we collect it?

Types of Data / Privacy Policy Scope

You may give us information about you and your child (the child for whom you have created the profile and has parental responsibility) by entering information on our app or website, allowing us access to data about you held by third parties, filling in forms, or by corresponding with us by phone, e-mail or otherwise. You may also give us information, and we may collect and process information about you resulting from, any interactions you undertake or services you request or source from us.

It will be clear at the time what personal information we are requesting from you. If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide the relevant Services to you, we will not be able to provide these Services to you. You don't have to provide data and can simply choose to stop using our app or website or our additional services.

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Sensitive personal data means any information related to the health of the individual.

We may collect, use, store and transfer different kinds of Personal data about you and your child, Sensitive personal data about your child, which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect:

If you sign up and create a profile for your child, this will include:

Identity data:

• First name, last name and gender of the child whose profile is created

• First name, last name and gender of the parent creating the account or the person with parental responsibility

Contact data:

Home address, telephone number and the email address of the account holder.

Health data (Sensitive personal data):

Medications, Allergies, GP and GP Practice name, Hospital name, Height, Weight, Blood group, GMFCS level, Background history, Active problems, Current Management, Treatment goals, Key interventions

Multidisciplinary health, care and education team data:

First name, last name, professional title, Service and organisation working for, Telephone number, Email address

Health, care and Education reports:

Reports, Management plans and Education, health and care plans (EHCP)uploaded by the account holder and by the professionals from health, social care and education

General information:

Appointments and Tasks related to managing the care of the child for whom the account is created

Technical data:

Each time you use our app or website we may automatically collect the following information:

• technical information, including (but not limited to) the type of device you use, a unique device identifier, mobile network information, your mobile operating system, and time zone setting and location.

• information either accessed through your device or stored on your device which you have explicitly consented to sharing, and the providence of that data including the device used to collect that data, time, date.

• details of your use of our app or website and services.

• the Internet protocol (IP) address, browser type and version, operating system and platform, and other technology on the devices you use to access EnrichMyCare platform and the mobile device from which you would be accessing the mobile apps

Communication data:

Your email for general, account specific and marketing communication purposes

If you purchase a product on the platform this will include:

Billing data:

Debit/credit card holder information (name/billing address) of whoever purchased something from EnrichMyCare (processed by Stripe)

Financial data:

We do not hold any explicit financial data about yourself. We rely on Stripe to retain and store your credit/debit card information and we do not retain it ourselves. However, in the course of your use of the Platform, you may state the any of the allowances that you may receive in relation to the child's disability. This data might provide some indication of the financial status. However, we are currently not actively seeking to analyse this information. If in future, we decide to do so we will inform you before we decide to use it.

Transaction data:

This includes details about payments from you for products and purchases you have made from EnrichMyCare. At the moment it’s just the subscription plan but if this changes we will share it with you before we collect any relevant information.

Research data:

If you have agreed to take part in our Research programme, we would be collecting baseline data, outcome data at different timelines. Alongside this we would be collecting aggregate data on the outcome of the Research study

Customer Support data:

If you contact us via email or through our contact forms, this includes feedback and survey responses. If you have done a webchat or contacted us by email or on live-chat, we will retain a record of that conversation

2.2. Usage data

This includes information about how you use our website, webapp, mobile app and any other products and services.

In the future we may also collect, use and share Aggregated data such as the usage of the splints, carrying out exercises, following treatment regime etc. When we do, we shall duly inform and ask your consent before we do.

Our 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. 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.

Further, we may use anonymous data collected from EnrichMyCare (Enrich Digital Technologies Ltd.) for site administration, analytics, advertising and promotional purposes. As of now, we don't share such information with other entities (such as service providers) for such purposes but if we do so, we will inform you to get your consent. We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal data, it does not identify you personally. EnrichMyCare may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners, health, care and education organisations.

We may use your anonymous data outside of EnrichMyCare to improve third party marketing or use your data in combination with third party data to improve your experiences both in and outside EnrichMyCare. We may retain your IP address and/or other device-identifying data in order to help us diagnose problems with our servers, to administer EnrichMyCare including personalizing content or links relevant to your geographic area or device-type, to verify that your account is not being used by others, to gather broad anonymous demographic data (such as the number of visitors from a geographic area), to enforce compliance with our Terms of Use for our Site, Terms of Service or otherwise in order to protect our services, Site, Platform, Users, or other third parties. We use analysis tools including Google Analytics, HubSpot and/or others. These provide us with information about how our users use the Site or Platform.

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.

3. Summary of personal and sensitive personal information collected and processed

We will collect, create and retain the following information to set up your account and security profile, and administer and maintain your account, including for any technical updates to or technical support for the application:

• Your basic account, your child's profile information, including your name, physical address, email address, telephone number, date of birth, and gender, along with any photos of your child that you choose to upload.

• Details of any support queries that you raise about technical issues you are experiencing with the application for which your email will be required to process your query.

• The username and password which you use to login to the application.

• Any other data that you choose to provide us with, other than through the usual functionality of the application. The main categories of information that you can choose to add to your child's Personal Health Record (PHR), and which will, other than as set out in the general sections of this Privacy Policy, be retained by us only for this purpose and in accordance with your preferences in the Trusted Access and Data Donor features, are:

• Your child's physical measurements, including but not limited to their height, weight, waist to hip ratio, muscle mass percentage, cholesterol, blood pressure, blood glucose, pulse, peak expiratory flow rate, oxygen saturation and respiration rate.

• Your child's medical history that you may include in the Personal Health Record, their diagnosis/conditions, injuries, allergies and other health problems that they have previously suffered, including any personal medical records that are disclosed to you by your GP or other healthcare professional.

• Any existing medical conditions, including any photos and videos that you upload that relate to the condition.

• Any medication that you provide, including the frequency in which it needs to be taken and the medical condition that it seeks to address and any historical medications that they have taken previously.

• NHS medical number of your child.

• The names and email addresses of PHR Contributors that you choose to receive information from.

• Any other relevant contacts, such as the name, address and telephone number of your child's GP.

• Any vaccinations details, including the name, date, location of the body they had the vaccination and any reminders for re vaccinations and boosters along with any notes or photographs you may have recorded.

• Any documents or letters you upload, including appointment letters, referral letters, reports, results or any other document you have chosen to upload.

• Any health data imported from other sources, devices or apps.

Where you use a third-party service via our app or website, we will pass only that information to them which is required for the functioning of that service. This will normally be information which allows the service to identify you as the originator of the request, and information relating to the specific service you are requesting. It will not generally include any information from your child's PHR; we will make it clear if it does. When you sign up for such a service, there may be additional terms of use and a privacy policy relating to that service, which you should read and understand before using the service. We will always try to be clear about exactly what information is being communicated between our services and others.

We may also receive information about you from third parties to facilitate provision of applicable Services. This may include information provided from your GP or other healthcare provider such as your child's name, NHS number and relevant contact details as well as sensitive information about you including your medical records. They provide such data to us to enable us to provide the services to you.

4. The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

Explicit Consent:

Where any of the personal and sensitive information we use contains data concerning health related information and racial or ethnic information, religious or philosophical beliefs, where you provide this data to us directly through your use of our app or website or applicable Services, we usually rely on you having provided us explicit consent to use such data when you provide us with this information. In some instances, we may rely on Public interest conditions or are required to process such data by law.

Furthermore, certain situations allow us to collect your Personal data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.

Legal obligation:

To make disclosures as required by or in compliance with reasonable requests by regulatory bodies or as otherwise required by law or regulation.

Legitimate interest:

• To review and enhance the quality of our services and products through details of your use of our app and website and applicable Services. This is in our legitimate interest to ensure we continue to improve the services we provide to customers.

• To allow us to respond to general enquiries and feedback from you. This is in our legitimate interest in providing a responsive service to customers.

• For internal operations, including analysis and reports, troubleshooting, detection of fraud, log data analysis, testing, security, audit and statistical purposes. This is in our legitimate interest to protect our business interests and assess and improve our business effectiveness.

• Where we rely on legitimate interest as a ground for processing your personal information, we carry out a "balancing test" to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the information contained in these balancing tests on request and can find out more by contacting us using the details below.

Third parties' data provided by you:

The User will have obtained consent from the third parties prior to entering the data into the Platform

5. How do we use your personal data (you and your child's)?

5.1. When will we share your personal information?

Information about you and your child is an important part of our business and we are not in the business of selling our customers" personal information to others. We share personal information only when its necessary to deliver our services, described below:

• Transactions Involving Third Parties: In the future, we may make available to you services, software, and content provided by third parties for use on or through the EnrichMyCare app or website. You can tell when a third party is involved in your transactions, and we will share the information related to those transactions with that third party. You will be given an opportunity to refuse to allow us to share that information.

• We may share insights we discover and your personal data, including your sensitive data, with specific 3rd parties including the NHS, health organisations, and academic and non-profit research institutions. If we share such data, we will always ensure it is in accordance with this Privacy Policy as well as our Data Processing and Retention Policies, and is subject to adequate and appropriate security measures, such as pseudonymisation (taking steps so you cannot be directly identified from the data shared). Wherever possible this data will be made anonymous prior to sharing.

• Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include sending communications, processing payments, analysing data, providing marketing and sales assistance and conducting customer relationship management. These third-party service providers may have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process that information in accordance with this Privacy Notice and as permitted by applicable data protection law.

• Protection of Us and Others: We release account and other personal information when we believe release is appropriate to comply with the law, enforce or apply our terms and other agreements, or protect the rights, property, or security of EnrichMyCare, our customers, or others.

• At Your Choice: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

We will not:

• Sell your personal or sensitive data to anyone else, without your specific consent.

• Give any third party direct real-time access to your data. We do not provide access into our system from outside.

• Share tracking IDs or cookies with advertisers, insurance companies, or any other third parties.

5.2. Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and by doing so opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

5.3. Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.4. How do we store your personal and sensitive information?

We will retain your child's personal information for as long as needed to fulfil the purposes of providing our services to you or for a period specifically required by applicable regulations or laws. For example, where you are registered for any of our Services, we generally keep your personal information for the duration of time you utilise that Service.

When determining the relevant retention periods, we will consider factors including:

• our contractual obligations and rights in relation to the information involved.

• legal obligation(s) under applicable law to retain data for a certain period of time.

• statute of limitations under applicable law(s).

• our legitimate interests where we have carried out balancing tests (see section on "How do we use your information above).

• (potential) disputes; and

• guidelines issued by relevant data protection authorities.

Otherwise, we securely erase or anonymise your personal information where we no longer require your information for the purposes collected.

6. Your rights and how you are protected by us

6.1. What Control Do I Have Over EnrichMyCare’s Use of My Personal Data?

You may delete your account at any time – this will remove your account page from the Platform and our related software. We do not guarantee the ability to delete all stored data. If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

You can access information associated with your account by logging into EnrichMyCare.

6.2. How Does EnrichMyCare Protect your data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems. Any Personal Data collected by us is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. Where sensitive data is collected by us it will be transmitted and protected via a secure protocol and encrypted in our databases to be accessed only as stated above. If and when we use subcontractors to store your data, we will not relinquish control of your Personal and sensitive data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of EnrichMyCare to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal and sensitive data, we cannot ensure or warrant the security of any Personal and sensitive data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us at [email protected].

6.3. Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by emailing us or by unsubscribing by clicking the link at the bottom of the marketing email. In the future we would provide you the option to log into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR once again by contacting us at any time.

Where you opt out of receiving these marketing messages, we will continue to retain Personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

6.4. How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity (for example we may ask how you are related to the child's data in question or any other form of validation) and ensure you have the 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

7. Your data rights and third parties

By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the data protection regulator in your country (ICO). You can exercise any of these rights by contacting us through our details below.

• The right to object to processing; you have the right to object to certain types of processing, including processing where we rely on our legitimate interest as a ground for processing.

• The right to be informed; you have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.

• The right of access; you have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.

• The right to rectification; you are entitled to have your information corrected if it is inaccurate or incomplete.

• The right to erasure; this is also known as "the right to be forgotten" and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions.

• The right to restrict processing; you have rights to "block" or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be "blocked" to make sure the restriction is respected in future.

• The right to data portability; you have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

• The right to lodge a complaint; you have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator (ICO). See details of the UK data protection regulator in the contact us section below.

• The right to withdraw consent; if you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). Note that such withdrawal in certain circumstance may mean we can no longer continue to provide the Services to you and your child.

• 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 baseless or excessive/repeated requests or further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.

8. How long we will retain your data for?

We will only retain your Personal and sensitive data for as long as reasonably necessary to fulfil the purposes we collected it for. For example, we are bound to retain the personal and sensitive information of a child for a longer period of time than an adult, or until they become an adult and an explicit consent is requested to continue to store beyond the age of 18. The conversations you have with us over email or through our live chat software will be retained while the matter is ongoing, but once our conversation ends, we may delete the record of that conversation.

We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We may share your Personal Data at any time if required for legal reasons or in order to enforce our Terms of Use for our Site/Terms of Service or this Privacy Policy.

9. Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

10. Age limits for our users

You must not use EnrichMyCare unless you are aged 18 or older. If you are under 18 and you access EnrichMyCare by lying about your age, or about your parental responsibility or are otherwise in breach of our Terms of Use for our Site or Terms of Service and this Privacy Policy, you must immediately stop using EnrichMyCare and terminate your Account.

This website is not intended for children and we do not knowingly collect data relating to children.

11. International transfer of data

We are currently storing data in the UK and so by using EnrichMyCare, you are permitting and consenting to only storing your data in the UK. If we plan to the transfer of information, including personal data, outside of the UK, we will duly notify you and get your consent.

12. Notification of changes and acceptance of policy

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated April 14th, 2021. By using EnrichMyCare, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of EnrichMyCare shall constitute your express acceptance of any modifications to this Privacy Policy.

13. Interpretation

All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g., FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of EnrichMyCare, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a EnrichMyCare address contradicts anything in this policy, our terms or any official public announcement on our website or is inconsistent with or amounts to a waiver of any EnrichMyCare rights, the email content shall be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the EnrichMyCare legal department.

14. Terms of use / Terms of service

Please also see our Terms of Use for our Site, and Terms of Service which set out the terms, disclaimers, and limitations of liability governing your use of EnrichMyCare.

Website Visitors:

If you are only a Visitor and have not subscribed to the application, then we will not usually ask you to provide any health, wellbeing or medical data. If we do, we will make it clear to you why we are asking for it and as appropriate, seek your agreement to use it. Please note that if you or someone on your behalf makes any public posts to message boards or social media about your health, wellbeing or medical circumstances, you will be regarded as having agreed to such publication.

However, we will collect the following:

• Contact information, including your name and email address in the event that you register interest in using our application.

• Any queries that you raise with us, for instance you may submit a question by email to us about our application.

• Any interactions that you have with us on any of our chosen social media platforms. For instance, you may decide to like our Facebook page or send us a tweet on Twitter.

• All other information that you choose to provide us.

• We may use the data that we collect about you in the following ways:

• Respond to your queries that you submit through our website or via any other communication medium such as email or letter.

• Contact you about the launch of the application where you have registered an interest in hearing about this.

• Help us to improve our website, including its content, layout and navigation.

• To verify your user credentials when you attempt to login to the application.

• Analyse user traffic and other metrics relating to the use of our website.

• Technical information, including (but not limited to) the type of device you use, a unique device identifier, mobile network information, your mobile operating system, and time zone setting.

15. Changes to this Privacy Notice

We update our privacy notice from time to time and any changes we may make to our privacy notice in the future will be posted on our application and website and, where appropriate, notified to you. The new terms may be displayed on-screen and you may be required to read and acknowledge them to continue your use of our website and services.

16. Contact Us

If you have any questions, comments and requests regarding this Policy, please get in touch with us:

Enrich Digital Technologies Ltd.
1 Mackworth Avenue
Littleover
Derby
DE23 3WB

Our email address is [email protected]

Data Protection Officer contact details:
Email: [email protected]

If you are not satisfied with our response to a complaint you have made, or think we aren't complying with data protection law, you can make a complaint to the UK data protection regulator - the Information Commissioner's Office:
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire
SK9 5AF
Phone number: 0303 123 1113
Email: [email protected]
Website: ico.org.uk/concerns/

Glossary

GDPR: The General Data Protection Regulation (EU) 2016/679 (GDPR)

Users: Any individual who either browses the public website, engages with our chat support feature, speaks with our employees and staff members, creates a profile for their child or uses our Platform as a signed-up user.

Personal Data: Information relating to an individual who can be directly identified from the information. Personal Data includes factual information as well as expressions of opinion or intentions.

Data Controller / Controller: The organisation that determines the manner and purposes for which Personal Data is to be processed. In our case, Enrich Digital Technologies Limited.

DPO: The Data Protection Officer.

Personal Data Breach: Loss, theft or unauthorised access, use or disclosure of Personal Data.

Privacy Policy: Our Privacy and Data Protection Policy

Aggregated Data: Statistical or demographic data derived from your personal data but not consider personal data in law as the data will not directly or indirectly reveal your identity.

Processors: Employees of Enrich Digital Technologies Limited authorised to discharge the responsibilities of the Data Controller.

If you have any other questions about the interpretation of this Privacy Policy, please get in contact with our DPO using the contact information above.

1. What are cookies and why do we use them?

A cookie is a small text file of letters and numbers that we place on your computer or device when you use our website. Cookies help us to collect data about you which, will in turn, distinguish you from other visitors and provide you with a good experience whenever you are using our website. The only cookies we use are from Google Analytics.

2. What types of cookies do we use?

Some cookies only last until you close your browser or for a short time after. These are called session cookies. Some last longer, for example, to enable a website to recognise you when you return to it. These are called persistent cookies. We use both session and persistent cookies to ensure that you get the best experience when using our website. There are also different types of cookies to collect different types of data about the way you interact with our website. We only use performance cookies. These are cookies that allow us to recognise and count the number of visitors we have and how these visitors use our Services (website, web app/platform and mobile apps). This data helps us to improve the way our Services works, for example, by ensuring that visitors or users find what they are looking for easily.

In the table below we set out the individual cookies we use and why we use them:

3. How can you manage cookies?

If the settings on your browser are adjusted to accept cookies we interpret this, along with your continued use of our website, platform or mobile app to mean that you agree to our use of cookies.
To manage or block cookies placed on your computer, mobile phone or tablet, you need to alter your browser or device settings. Please consult your browser’s guide or visit www.allaboutcookies.org for more information or refer to your device user manual.

4. Third parties

Please note that third parties (including, for example, health, care and education providers, charity websites and other external links) may also use cookies, over which we have no control. These cookies are likely to be performance cookies or targeting cookies. If you are concerned about cookies from third parties, you can often opt-out with the provider directly (such as with Google Analytics, please visit https://tools.google.com/dlpage/gaoptout ). Please note that these providers may use cookies to power their opt-out service, so if you change your browser settings to block all cookies, their opt-out service may cease to work.