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1. Marketing

1. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
2. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
3. We strive to provide you with choices regarding certain personal data uses, namely around marketing and advertising. In particular:

a. We will always obtain your express opt-in consent before we share your personal data with any third party for marketing purposes; and

b. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to your or by contacting us at any time.

2. International transfers

1. Your data is stored by us in the UK or the European Economic Area (EEA). However, several of our third-party processors are based outside UK and EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. We will either:
   1. transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
   1. ensure that standard contractual clauses (SCCs) are in place and we have received assurances that an adequate level of protection of the personal data is achieved (based on a case by case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data.
2. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

3. Data security

1. 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.
2. To protect individuals requiring care, Consumer Profile Data will be anonymised at all times.
3. 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.

4. Data retention

1. We will only retain your personal data 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 if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
2. 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.
3. By law we have to keep basic information about our clients (including Contact, Identity, Data) for 6 years after they cease being clients.
4. In some circumstances you can ask us to delete your data (see below for further information).
5. We may 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. Please see clause 3.2.

5. Your rights

1. Under the data protection laws your rights are:

1. To be informed – We must make this privacy policy (sometimes referred to

as a privacy notice) available to you and be transparent over how we process

your data.

• Access – You are entitled to know what details we hold about you and why.

We strive to be as open as we can be in terms of giving people access to their personal data. You can find out if we hold any of their personal data by making a formal request under the data protection laws. Such requests should be made using the contact details provided in this policy. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing. Our response will:

i. confirm that your data is being processed;

1. verify the lawfulness and the purpose of the processing;
2. confirm the categories of personal data being processed;
3. confirm the type of recipient to whom the personal data have been or

will be disclosed; and

• let you have a copy of the data in format we deem suitable or as

reasonably required by you.

c. Rectification – We are obliged to correct or update your details. We will

correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.

• Erasure – This is also known as the right to be forgotten. Under Data Protection Laws you have the right to require us to erase your personal data under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
• Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
• Portability – You have the right to obtain the personal data that you have provided to us in a commonly used machine-readable format and reuse it with a different provider.
• Object – You have the right to object to us processing your data in certain circumstances. You have an absolute right to stop your data being used for direct marketing, but in other circumstances we may still be allowed (or required) to process your personal data if we can show you that we have a compelling reason for doing so.
• Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
• Withdraw consent. Where you have given us consent to process your personal data, you can withdraw that consent at any time either by contacting us using the details set out in this policy, or by following the opt-out links in electronic messages where relevant. We do not penalise individuals who wish to withdraw consent and we act on withdrawals of consent as soon as we can.
• Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the data protection laws and as summarised above.
• If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

6. APPLICATIONS to work for us

If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.

7. Subscription and Payment

Where4Care charge a one off fee of £50.00 (plus Vat), to upload and register your company to our online platform. This fee is to cover the admin costs incurred to Where4Care. To keep your profile, live and to have access to all features within, there is then a monthly subscription of £20.00 pcm (plus Vat). This fee is paid monthly Via direct debit in advance. This is a yearly subscription. Following the year, you may cancel, however due to waiting lists you may not be able to be re-added to the platform.
If cancelled, you profile will automatically be deleted on the next renewal period. If you decide to re-join after cancelling, the £50 plus VAT charge will be re-payable to make your profile live again. We also have an option to pay the subscription 12 months in advance for £264.00 (including Vat), giving you one month free. Please contact W4C directly should you wish to take advantage of the offer.
We do not permit providers to add their own phone number, email or web address/social media links.  Once you are verified and we partner a lead, all contact details will be shared.

For more information you can contact our subscriptions team on: info@where4care.co.uk