Last Updated: March 2021
We are committed to protecting the privacy of our Users.
Elunow is an online application for ordering home and personal care services that deliver requests for care services to care service providers who have joined the Elunow system. The Elunow application's rights holder and provider of services are the CareMate OÜ (registry code 14385848), established in the Republic of Estonia.
All your Personal Information shall be used in accordance with the General Data Protection Regulation (GDPR). For the purposes of the GDPR, CareMate OÜ is the data controller, where you are visiting or using our services through our Website (Elunow.com) or accessing our mobile applications.
The basis for the processing of your data
Elunow processes your data for the performance of the contract that you have entered into with Elunow for the use of the Elunow service and that is governed by our Terms and Conditions, and/or in order to take steps at your request to enter into this contract.
When it comes to special categories of data such as health data, we rely on Article 9(2)(h) GDPR exception in connection with Schedule 1, Part 1 of the Data Protection Act 2018, pursuant to which we can process the data for the provision of social care services.
In addition, some data is processed based on Elunow legitimate interest, notably safety and security of care seekers and care assistants, web and app analytics for the purposes of enhancing web and app performance, website logs, etc. to prevent fraudulent or other malicious activities, website visitor logs for cybersecurity and/or error tracking purposes.
We may ask for your consent in other cases where we process your data. Such consent can be revoked at any time by contacting us at firstname.lastname@example.org
1. Policy Updates
2. Information collected
2.1 Personal information
Personal Information is information that could potentially identify you individually. We may collect, store and/or use the following types of personal information:
2.2 Personal information relating to care receivers
This might be where the Care Seeker and the person receiving the Care (the “care receiver”), is not the same person, and as such you might disclose personal information about them.
2.3 Additional personal information collected for care assistants
If you are using the Website/Platform to apply or join as one of our registered care assistants, we will collect and store further personal information, including but not limited to:
Information might be provided; directly from you; from a third-party hiring platform or job board, to which you uploaded a CV or other personal information to; or, where you have been referred to us to work through the platform; or engaged with us via social media channels. We will not use data from the open internet in this regard; we will only gather information about you where you have previously intended to let us know. Personal information collected from social media channels may include that which is detailed on your profile such as; name, location, work details.
We may collect data and feedback from clients and reference it against your profile as this is important for the safety of Users. This information will not be publicly available on your profile.
2.4 Other Information Collected – technical and technology information as it relates to your data:
3. Using your Personal Information:
3.1 For All Users:
We and our representatives may use your personal information for the following purposes:
We will not provide your information to any third parties for direct marketing purposes without your express consent.
3.2 For Care Seekers and care receivers - Additional Information:
We and our representatives may use your personal information for the following purposes:
3.3 For care assistants - Additional Information:
Where you have applied to join or have been accepted as a registered care assistant on the Website/Platform, you submit personal information to us and for publication on our Website/Platform and as such we may use your information in accordance with our Terms & Conditions.
We may use this personal information in the following ways:
Customers can search for Caregivers in their local area on our website, using a postcode search, and can view limited profiles of those in their area. The limited profile includes: picture, first name, surname (initial only), years’ experience in care, driving status, pet preference and languages. Customers will not receive any further details or contract details until you propose yourself to a job.
When you propose yourself for a job, your personal profile is made available to the family, which includes: full first name, surname (initial only), picture, summary key info and background checks info (DBS checked, driving or car status, languages, pet preference, public liability status, smoking or not), condition experience, services provided, qualifications and a map with a broad indication of where you live. Once the family receives the “shortlist of carers”, they may want to interview you; in that case, Elunow will share your contact details: phone number and email.
4. Retention of personal data
The Platform allows Users who are care seekers to connect with Users who are care assistants and provides tools to help facilitate this process. As such it is vital, we retain personal data on Users and from closed accounts for as long as necessary to fulfil the purposes the data was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements and to comply with other obligations such as safeguarding Users, to the extent that it is permitted by Law.
We may delete accounts or specific information before account deactivation where we believe it may no longer be relevant or where an account has been inactive for more than a year.
If you have sent us an email or other correspondence, we will retain your information until we are satisfied it is outdated or no longer relevant, subject to your exercise of the right to erasure.
5. Disclosure of your information:
Subject to the need to perform the contract with you based on our Terms and Conditions and our legitimate interests, we may share your personal information in the ways described below:
We do not allow our third-parties to use your personal data for their own purposes (such as marketing or reselling) and we only permit them to process your personal data for specified purposes and in accordance with our instructions. Recipient category and explanation as follows.
Prospective seller or buyer of our business or assets
Other companies and organisations
Where we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply such other terms as apply to our relationship, or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction and relating to safeguarding issues.
Social Services, Adult Safeguarding Board of the relevant Local Authority, General Practitioner (GP), NHS clinicians or nurses, private consultants, specialists or other persons involved in your ongoing Care
If we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Platform or if we are under a legal obligation.
Third-party tools, software and service providers: hosting, analytics, CRM, emailing, payment, scheduling, administration and support, app integration, communication, identity verification, system administrators
We may share your personal data with third-parties who perform functions on our behalf in connection with the operation of our business and assist us in the communication with you, the performance of the contract you have entered into with us and the improvement and optimisation of our website.
Certain parts of Our Website/Platform use “cookies” to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store on your computer’s hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited.
Types of cookies used on Elunow:
Elunow uses different types of cookies. Permanent or persistent cookies are those that are not removed from your browser or computer after a session ends and you close your browser. These are used to recognise you as a User and for example remember the details about care requests made by a User to enable sign up functionality, should the User leave and return to the site. Session cookies enable us to track you while using our Website and for example make care bookings.
Elunow uses a number of third party services to embed content such as reviews and videos, and to help analyse site features and are primarily for own internal purposes. An example of this would be Google Analytics, which provides information, insights and reporting on the use of the Website.
Our Service has numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We do take data security seriously and will use our reasonable endeavours to protect the integrity of your personal information.
Additionally, personal information and content requested may be transmitted electronically to addresses provided by you (email for example) and this is done so at your own risk and you understand these risks.
8. Storing Your Personal Data
Your personal data may be collected, processed and/or otherwise transferred to a destination outside the European Economic Area (“EEA”) and in particular, the United States.
Data we collect from you is primarily stored on servers located in the EU/EEA, however in particular third party technologies and services we use may store data in the United States, which results in this transfer of information internationally outside of the EEA. Please see section 9 for further information.
We will take all reasonable steps necessary to ensure that your data is treated securely and appropriately in accordance with this policy.
We have put the necessary steps in place to ensure all company laptops are encrypted and have appropriate protection against viruses, malware, ransom-ware and malicious code and are regularly updated.
9. International Data Transfers
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), where the laws on processing personal data may be less stringent than in your country. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
10. Your rights:
You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
Access - You are entitled by law to ask for a copy of your personal information at any time free of charge.
You have the right to obtain without undue delay the rectification of inaccurate personal data concerning you, including the right to have incomplete personal data completed e.g. by means of providing a supplementary statement.
You have the right to erase your data, which you can exercise by means of the deactivation of your account. We are not required to delete the information important for the establishment, exercise or defence of legal claims, or that we need to retain in order to comply with the law.
You have the right of restriction of processing, where the data is wrongfully processed but should not be erased for a reason listed in Article 18 (1) of the GDPR. Until a download option has been developed based on universally recognised standards, you may exercise your right of data portability by obtaining your data by sending us an email request.
11. Third party websites
12. Our Contact information