Privacy

General

• This Privacy Policy (“Policy”) refers to Gazelle Web-Tech and you, the user of the Care Agency Management Application (C.A.M.A).
  • Us, We, Our – Gazelle Web-Tech is the publisher and operator of the web app https://www.camapp.org.uk, and is referred to as “C.A.M.A”. “us”, “we”, “our”, “ours”, etc. refer to C.A.M.A. as the “web app”.
  • You, the User - This Policy will refer to the user as “you” or “yours”, etc.
• This Policy describes how we use information received about you when you visit our web app or when you subscribe to, or otherwise use our online services. This Policy does not cover any information that we may receive from or about you through channels other than through the use of C.A.M.A.

Policy acceptance

Your acceptance of the policy is deemed to occur upon your first use of the web app. You are required to read and accept this Privacy Policy when you engage with us.
C.A.M.A may change this policy from time to time by updating this page. On each visit, you should refer to this page to ensure that you are aware of and accept any changes.

Information we collect

We may collect, use, store and transfer different kinds of personal data about you when we engage with you. Depending upon your level of interaction, we will collect different information about you. We collect information about you directly from you, as well as automatically through your use of C.A.M.A. The type of information collected is as follows:

• Identity Data - title, first name, last name, date of birth or similar identifiers.
• Contact Data - billing address, delivery address, email address and telephone numbers.
• Financial Data – bank account and payment card details.
• Transaction Data - details about services you have purchased from us.
• Technical Data - includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data – your email and password, purchases made by you, your interests, preferences, images uploaded, qualifications and references, feedback and survey responses.
• Geographical Data - information setting out your primary address to control the use of location services in most mobile devices and desktop settings.
• Usage Data - information about how you use C.A.M.A.

How we collect data.

We use different methods to collect data from and about you, through the following:

• Registration: Personal details provided during the registration process on the web app are collected so that we can register you and respond to your communications with details of our services. Once registration is completed, data is used on an ongoing basis to enable you to continue to access C.A.M.A during your trial or as a subscriber to its services. This may include details of service updates and promotions.
• Emails: We retain copies of emails sent to us and any personal data will be held in accordance with this Privacy Policy on the basis of being legitimate to our business interests.
• Telephone calls: Calls to us may be recorded and any data relating to the call may be retained by us.
• Other direct interactions: You may give us your personal data by filling in forms or by corresponding with us face-to-face, by post, through social media or online live chat. This includes personal data you provide when you: sign up to receive our services; make enquiries or request information be sent to you; use our services; ask for information to be sent to you; engage with us on social media; contact us directly; or leave comments or reviews on our services.
• Social media: We use social media to engage with users and link to our Facebook, LinkedIn and Instagram pages. We do not keep any specific data that identifies you as an individual user but hold details of our followers on these platforms. You should refer to the Privacy Policies of these channels to understand how they treat your data in relation to linking to our site: If you send us a direct message via social media, the details may be retained by us only as relevant to any ongoing contract or to further our legitimate business interests or as required for legal purposes. The third-party provider may also retain details in accordance with their Privacy Policy.
• Reviews: We may ask for a review of our services and these may be published on social media. We may publish your name, position in the company and company name if provided with these details.
• Visits to our web app: When you visit C.A.M.A, we do not attempt to identify you as an individual user, and we will not collect personal data about you unless you specifically provide this to us. As you interact with C.A.M.A, technical data may be automatically processed through the use of Cookies, details of which are explained in our Cookie Policy.
• Special categories of data: We do not generally 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).
• Children: We do not market C.A.M.A to those under 18 years old. Consistent with the GDPR we will never knowingly request personally identifiable information from anyone under the age of 16 years old. We will take appropriate steps to delete any personal data of individuals less than 16 years of age that has been collected on C.A.M.A upon learning of the existence of such data.

Information we get from other sources

From time to time, we may need to obtain information from third parties about you. This will only apply where it is necessary to provide our services and as permitted by law. We may receive personal data relating to your identity and contact data from data partners; and data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.

How we use your information

UK data protection law requires us to have a “legal basis” for processing personal data. The legal basis we rely on are:

• Performance of a contract we are about to enter into or have entered into with you.
• Compliance with a legal or regulatory obligation.
• Carrying out activities that are legitimate to our business interests.
• Consent. However, generally, we shall not rely on consent as a legal basis for processing your personal data other than where the law requires it. Where our legal basis is consent, you have the right to withdraw consent any time.

Users contacting C.A.M.A and/or its owners do so at their own discretion and provide any such personal data requested at their own risk. Your personal data is kept private and stored securely until a time it is no longer required or has no use.

Our legitimate interests: When we use our legitimate interests as the legal basis for processing your personal data, we will consider and balance any potential impact on you and your rights before we process your personal data. We will only then proceed where we believe our interests are not overridden by the impact on you. Our legitimate interests include the management of our business operations.

Sharing information

Disclosure: We don’t share, sell, or distribute your data to third parties, except as contractually agreed with you or as provided in this Privacy Policy. We may disclose your personal data if we are required to do so by law, in connection with any legal proceedings, and in order to establish, exercise or defend our legal rights, or if otherwise legally permitted.

Marketing: We may carry out direct marketing by email, phone, text or post. We will ask for your consent to receiving marketing communications (including newsletters) when you register on the website and you have the option not to give consent and to withdraw consent given at any time. You may withdraw your consent for us to contact you by email at privacy@gazelleweb-tech.com. We may continue to contact you for non-marketing purposes if there is another lawful basis to do so.

External links: Users of C.A.M.A are advised to adopt a policy of caution before clicking on any external web links. Clicking an external link will take the user away from our web app. Once you leave C.A.M.A or are redirected to a third-party website, plug-in or application, you are no longer governed by this Privacy Policy or our terms and conditions. We cannot guarantee or verify the contents of any externally linked website and users click on external links at their own risk. C.A.M.A and its owners cannot be held liable for any damages, or the consequences of visiting any external links.

Social media platforms: Communication, engagement and actions taken through external social media platforms that C.A.M.A and its owners participate on are subject to our terms and conditions as well as the privacy policies held with each social media platform respectively. Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. Neither C.A.M.A nor its owners will ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

Payment processing: Payment for our services is processed online through the application of our payment provider, Stripe, and all data is safeguarded and handled in accordance with recognised industry standards. You can refer to their Privacy Policy here.

Data retention

We keep your personal data in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and data will be disposed of when no longer required.

Data security

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, personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. We take appropriate steps to ensure a safe processing of personal data, however, we cannot guarantee the security of data transmitted through C.A.M.A or by email. Any transmission is at your own risk.

Data storage

Any information that you supply to us may be stored and processed by our web APP host, Vultr Web Services (Europe). Your data may be transferred in accordance with the policies of Vultr Europe and under relevant data protection law. You can refer to their Privacy Policy at Vultr.

Right of data subjects

C.A.M.A recognises a data subjects rights and will uphold these in accordance with data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from:

• the date that we have confirmed your identity.
• where we do not need to do this because we already have this information, from the date we received your request.

Subject Access Requests: You have the right to ask for a copy of the information that we hold about you by emailing us at privacy@gazelleweb-tech.com. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information. In limited circumstances a fee may apply.

Right to rectification: Data subjects have the right to request that personal data is amended or changed if it is inaccurate or incorrect. We act on any such request without delay.

Right to erasure: Data subjects have the right to ask us to delete personal data from our systems without giving any reason and at any time. We act on any such request without delay.

Right to restrict processing: Data subjects have the right to rectification or erasure of personal data in the following circumstances:

• Personal data is not accurate.
• The processing of data is unlawful.
• Data is required to exercise legal rights or defend legal claims.
• Data is unlawful, although there may be lawful grounds for processing, which override this right.

Right to data portability: Data subjects have the right to obtain and request the transfer of their data to different service providers.

Right to object: Data subjects have the right to object to the processing of personal data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data under lawful grounds.

Right not to be subject to decisions based on automated processing: We do not use any automated processing that results in any automated decision based on a data subject’s personal data.

Using your rights: If you wish to invoke any of these rights, you should contact the person responsible for data protection by emailing us at privacy@gazelleweb-tech.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Data breaches

We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication.

Changes to our privacy policy

We reserve the right to change this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. You will be deemed to have accepted any changes to the terms of the privacy policy on your next visit of the website following the amendment.

Reporting Complaints

If you want to raise a concern about the use of your data, you can contact us by email at privacy@gazelleweb-tech.com