Privacy Policy

1Who we are

LivWell Companions ("LivWell", "we", "us" or "our") is a companionship introductory agency serving families across London. We find, vet and introduce independent, self-employed companions to older adults and their families. We are not a care provider, and we do not employ the companions we introduce.

LivWell Companions is the controller of the personal information described in this policy. That means we decide how and why it is used.

Name

LivWell Companions

Address

[Registered business address]

Email

livwellcompanions@gmail.com

Phone

[Phone number]

ICO registration

[ICO registration number]

2Who this policy covers

This policy applies to our website and to our services, including consultation requests, companion applications, vetting, introductions, payments and support. It covers:

• families and other people who contact us on behalf of someone else, or for themselves;
• the person who will receive companionship;
• people who apply to become companions, and companions in our network; and
• visitors to our website.

If you give us information about another person, such as a parent or relative, please make sure you are entitled to do so and that they know we will use it for this purpose. Where possible, please show them this policy.

3What we collect

Families and enquirers

• Your full name, email address, phone number, and your relationship to the person who will receive companionship.
• Your address or area, and how you found us.
• Notes from calls, consultations and messages.
• Payment details when you pay us. Card payments are handled by Stripe, and we do not see or store your full card number.

The person who will receive companionship

• Their full name, age, and the area where they live.
• Their personality, interests, routine, preferred schedule and the kind of companionship wanted.
• Whether they have pets at home, and whether a companion would need to drive them anywhere, with the details you give us.
• Any health, mobility, memory or support needs you choose to tell us about, so that we can match safely. This is sensitive information (see section 5).

Companion applicants and companions

• Name, contact details, date of birth and address.
• Work and companionship experience, references, and notes from our interviews, including virtual interviews.
• Proof of identity and right to work, and the result of our checks.
• Driving details if relevant, such as whether you hold a valid UK licence, have a car available and have business-use insurance.
• The services you offer, your availability and the areas you can cover.
• The result of a background check, which may include criminal record information (see section 5).

Website visitors

• Technical and usage information such as your IP address, browser, device type, the pages you visit, which site or search led you to us, which buttons you click, and whether you start or finish one of our forms.
• Information held in cookies and similar technologies (see section 11).

Where it comes from

Most information comes from you. We also receive information from the family of a person receiving companionship, from companions' referees, from our identity and background check providers, and from the tools that run our website.

4How we use it, and our legal reasons

UK data protection law says we must have a lawful reason for each way we use personal information. The table sets out what we do and the reason we rely on. Where we rely on legitimate interests, we have weighed them against your rights and interests.

We do not make decisions about you using only automated means. Matching is done by people at LivWell.

5Sensitive information

Some information needs extra care under the law.

Health and similar information

Details about someone's health, mobility, memory or support needs are "special category data". We use it only to understand what kind of companionship is suitable and to make a safe match. We ask for your explicit consent before we do, usually by a tick box on our consultation form. You can withdraw your consent at any time by contacting us. If you do, we may no longer be able to continue a match, and we will explain what that means before we stop.

Criminal record information

When we run a background check on a companion, we receive information about criminal convictions and offences. The law gives this extra protection. We use it only to decide whether a person is suitable to join our network, relying on conditions in Schedule 1 of the Data Protection Act 2018 such as protecting the public and safeguarding individuals at risk. We keep an appropriate policy document that explains how we handle it, and we restrict access to the people who need it.

Where we need to tell you something about our assessment of a person, we share only what is necessary and lawful.

6Who we share it with

We share personal information only where we need to, and only what is necessary.

• The companion or family we introduce. We share enough for both sides to decide whether to meet and, if they agree, to start. See section 7.
• Service providers that work for us. These include Stripe for payments, our website platform (Base44) and its hosting, Google for email and file storage, video-call tools for interviews, an identity checking provider, and our background check provider [Background check provider]. They may use the information only to provide their service to us, under written terms.
• Professional advisers such as lawyers, accountants and insurers.
• Authorities. Where the law requires it, or where we have a genuine safeguarding concern, we may share information with the police, local authority adult safeguarding teams, the Disclosure and Barring Service or other regulators.
• A future owner. If LivWell is sold or reorganised, we may pass information to the new owner, who must use it in line with this policy.

We do not sell your personal information, and we do not share it with third parties for their own advertising.

7After an introduction

LivWell makes introductions. Once a family and a companion decide to go ahead, they agree the rate, hours and arrangements between themselves, and the companion works as an independent, self-employed person.

From that point each of them is responsible for how they use the other's personal information. We ask both to use it only for the companionship arrangement and to keep it confidential. We are not responsible for information they exchange outside LivWell. If you ever have a concern about how a companion or a family has handled information we passed on, please tell us, and we will help where we can.

8Transfers outside the UK

Some of our service providers may process information outside the UK, for example in the United States or the European Economic Area. When this happens, we make sure the transfer is protected. We use countries that the UK government has approved, certified schemes such as the UK extension to the EU-US Data Privacy Framework, or the UK's standard contract terms. In every case the protection must be of a standard that is not materially lower than the protection you have under UK law.

You can ask us for more detail about the safeguards we use by contacting us (section 18).

9How long we keep it

We keep personal information only for as long as we need it for the reasons we collected it, and then delete or anonymise it. These are our usual periods.

We may keep information for longer if the law requires it, or if we need it to deal with a legal claim or safeguarding matter.

10Keeping it secure

We protect personal information with measures that fit how sensitive it is. These include limiting access to the people who need it, using passwords and secure accounts, encrypted connections for our website and the tools we use, choosing providers with good security records, and keeping vetting records apart from general enquiries.

If there is a breach that puts your rights at risk, we will tell the Information Commissioner's Office within 72 hours where the law requires it, and we will tell you directly if the risk to you is high.

11Cookies and similar technologies

Our website uses cookies that are essential for it to work. We also use basic statistics to see how the site is used, such as page views, visits, where visitors come from, button clicks, and how many forms are started and finished. The law lets us do this without consent as long as we tell you and give you a free and simple way to opt out, and you can opt out at any time. We use any other cookies only if you agree. Our Cookie Policy lists each cookie, what it does and how long it lasts.

12Marketing

We send marketing emails only if you have agreed to receive them. Every message has a link to unsubscribe, and you can also tell us at any time. We will still send you messages that are part of the service you asked for, such as updates about an introduction.

13Your rights

You have the following rights over your personal information.

• Access. You can ask for a copy of the information we hold about you and details of how we use it. We carry out a reasonable and proportionate search to find it.
• Correction. You can ask us to fix information that is wrong or incomplete.
• Deletion. You can ask us to delete your information in some circumstances.
• Restriction. You can ask us to pause our use of your information while a concern is looked at.
• Objection. You can object to us using your information where we rely on legitimate interests, and you can always object to direct marketing.
• Portability. You can ask for information you gave us in a format you can reuse, where we use it under a contract or with your consent.
• Withdrawing consent. Where we rely on your consent, you can withdraw it at any time. This does not affect what we did before.
• Automated decisions. You have rights around decisions made solely by automated means. We do not make such decisions.

To use any of these rights, email livwellcompanions@gmail.com. We may ask you to confirm who you are. If you are asking on behalf of someone else, we will need their written permission or proof that you have legal authority to act for them.

We reply within one month. If your request is complicated or we have received several, we may take up to two more months, and we will tell you why. There is normally no charge. These rights do not always apply in full, and if we cannot do what you ask, we will explain why.

14Complaints

If you are unhappy with how we have handled your personal information, please tell us first. You can complain by email to livwellcompanions@gmail.com, by phone [Phone number] or by post to the address in section 1. You do not need to use any particular words. Any concern about how we have handled your information counts as a complaint.

We will acknowledge your complaint within 30 days, look into it properly and keep you updated. We aim to give you an outcome without undue delay and within three months, and we will tell you if it will take longer and why.

15Children

Our services are for adults and our website is not aimed at anyone under 18. We do not knowingly collect information from children. If you think a child has given us information, contact us and we will delete it.

16Other sites and social media

Our website links to other sites, including our Facebook and Instagram pages. Those services have their own privacy policies, and we are not responsible for how they handle your information. If you message us through social media, the platform also collects that information, and we recommend moving to email or phone for anything private.

17Changes to this policy

We may update this policy when our services or the law change. The latest version is always on this page with its date at the top. If we make a significant change, we will tell you by email where we have your address, or by a notice on our website.

18Contact us

For any question about this policy or your information, or to use your rights, contact us.

LivWell Companions

Privacy enquiries

Email

livwellcompanions@gmail.com

Phone

[Phone number]

Post

[Registered business address]