Privacy Policy

Last Updated: March 2021

We are committed to protecting the privacy of our Users.

Please read this Privacy Policy carefully as it contains important information about our practices - how we will collect, use and share your personal information, information that we collect from you, and that we receive from third parties.

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.

This Privacy Policy applies to both care seekers and care assistants, and, with regard to transparency provisions according to General Data Protection Regulation (GDPR), to other individuals whose data we may process when visiting our Website (Elunow.com) or accessing our mobile application, except for our employees.

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 info@elunow.com

1. Policy Updates

From time to time this Privacy Policy may be updated and a new version will be posted on our Website/Platform. As such you should check this page to review the changes and ensure that you continue to agree to the Policy. The date the Policy was last updated will be displayed at the top of the page.

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:

  • Information that you give to us. This might be that which you provide via forms on; the Website, the Platform, or provided by e-mail, over the phone or other such means.
  • This includes information provided for the purpose of registering for or using our service, in searching our Website or Platform, in subscribing for our services (email notifications and/or newsletters) or for any other reason. This includes but is not limited to;
    • Contact information: your name, email address, and phone number
    • Information about the Care needed: the type of Care, the address where the Care is required, and the name of the care receiver.
  • Information relating to any transactions made through the platform, including but not limited to booking or providing the Care and corresponding financial and credit card and billing information.
    • We do not store Credit or Debit card information submitted through the Platform to pay care assistants and our booking fee. This payment information is transmitted directly to a third-party payment card processor, Stripe. Please find their Privacy Policy here.
    • Stripe notifies us whether your transaction Payment has been successful or not, and might communicate some details on issues, for example, if a payment fails due to insufficient funds or other reasons.
  • Information provided on health and/or medical conditions, experience requirements, and personal preferences.
    • In addition care assistants may record information about Care provided, care seekers and care receivers in the course of their service delivery, which is connected to your account and other personal information provided. This information may be stored and made available to other care assistants booked for the purposes of best serving you.
    • Special categories of personal data like health data, which merit higher protection, will be processed for health-related purposes only where necessary to achieve those purposes for the benefit of care receivers, in particular in the context of the management of health pursuant to contract with a health professional and subject to suitable safeguards. care assistants’ health information will be processed in terms of ensuring care seekers and care assistants’ own security when providing the services.
  • Ratings and reviews provided – about services provided through the platform, including about the care assistants.
  • We may also receive and store information about you from third parties, involved in or connected to the Care, such as Social Services.
  • We may receive and store information about you where you interact with us through social media. This will include personal information that is available on your profile such as; name, location and work details.

2.2 Personal information relating to care receivers

Before disclosing to us any personal information relating to another person you must obtain their consent to the disclosure and processing of that information in accordance with the terms of this Privacy Policy. We reserve the right to take reasonable security steps to ensure that the care receiver is aware of the data processing, which may result in asking for further information/documentation.

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 you supply to us during the application process and thereafter. Personal data such as:
    • Qualifications, professional skills and other experiences (CV), personal preferences (activities of daily living you enjoy or animal preferences), nationality, languages, results of background checks (see below) and any other personal data which you disclose to use for use in your profile.
    • A photograph of your face, which we may take for you and display on your profile to care seekers. A photograph of your face is required in order that the Care Seeker can know who the person they are booking is and identify them when letting them into their home. This is important for the safety and security of Users.
  • Supplemental information about you from third parties, for example, results of background checks, Enhanced DBS (criminal records check including spent convictions), identity and right to work checks. The results of these checks will be shared with us by the third-party provider. Information obtained for the purposes of verifying your work history and reference checks or that information obtained by way of face to face interview.

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:

  • We may collect and store certain information automatically through technology each time you visit the Website or Platform. This is typically designed to help us learn and improve the way we serve you. Examples of this information include the following:
    • information about how you interact with the Website/Platform - the computer or device used for access, the internet protocol (IP) address used to connect your computer or device to the internet, other connection information such as: browser type, version, location and language preferences, and your operating system
    • information about your visit including: referral source, page visits, duration and navigation information, searches made, the full Uniform Resource Locators (URL)
    • We also may receive information about you from other third parties we work with - such as any websites or social media platforms (for example, Facebook), other advertising and analytics networks, and other channels that link Your Personal Data to our Website/Platform.

3. Using your Personal Information:

3.1 For All Users:

We and our representatives may use your personal information for the following purposes:

  • carrying out our obligations under Our Terms & Conditions;
  • authorising payments and/or a bill or receipt to or from you;
  • administering and maintaining the account you hold with us;
  • ensuring that Our Service is presented in the most effective manner for you and your computer or mobile device;
  • providing you with information, products and/or services that you request from us, and other commercial communications;
  • where you have consented and opted into specific communications such as those for direct marketing purposes, information about other services or products which we feel may interest you;
  • notifying you about a change to Our Service;
  • record-keeping and tracking your use of Our Service including through the use of cookies;
  • requesting feedback on Services and to address and investigate service complaints that might arise or violation of any of our Terms, Policies or Standards; and
  • to conduct troubleshooting, data analysis and internal reporting

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:

  • ensuring care assistants can fulfill a booking;
  • providing care assistants with relevant details of the Care previously booked and the records of other care assistants providing Care to the care receiver
  • providing care assistants with information stored on your account about: health and medical needs, experience requirements and other personal preferences including activities of daily living
  • Once you have completed your care request, we will share the following information with the suitable carers in order to find the best match for you: first name, first three digits of the postcode where care is required and the description of needs.
  • Where you are referred to us by an insurance company or business partner, we may exchange with them basic information to identify you, such as your insurance policy number. We may further share with the insurance company aggregate basic information regarding the care type that has been requested Care seekers matching with third party care services
  • Where you agree for us to refer you to a third-party Care services provider, such as a Care or nursing agency, we will share pseudo-anonymised information for the purpose of meeting your requirements as a Care Seeker. The agencies who can meet their need will be presented to you and you can then choose whether Elunow shares their full information with a chosen care provider for them to contact you directly, or whether they would prefer to receive the contact information of the relevant agency so they can contact you directly. If you do not agree for us to share your information we will share the agency's information directly with you.

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:

  • inviting you to apply or to complete your application;
  • to contact you in respect of an application to join the Platform – such as arranging an interview, induction or any training;
  • to assess your CV, qualifications and any other information provided to ascertain your suitability to join the platform;
  • to complete the registration process, including contacting third parties to obtain references on you;
  • to provide you with information regarding job opportunities with care seekers that may be of interest to you based on the information we have collected;
  • to monitor your ongoing compliance and administer your account including: criminal records information shared with us by our third-party DBS provider, RTW documentation, updates to training and other compliance information;
  • to check the status of your DBS certificate on a weekly basis if it is registered online with the DBS Update Service, using their Multiple Status Check Facility;
  • to provide your profile to care seekers to facilitate a booking, which is available on the internet.
  • to provide your details to care organisations in the Home Instead franchise network for other job opportunities that may be of interest to you.

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

Just in the event that we sell or buy any business or assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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.

6. Cookies:

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.

We use cookies on Our Website/Platform to enable us to deliver content that is specific to your interests and gives us an idea of which parts of Our Service you are visiting and to recognise you when you return to Our Service. Our cookies do not read data from your computer’s hard-drive or read cookies created by other websites that you have visited.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access Our Service. Please note Third Party, providers of content and services may also use cookies over which we have no control.

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.

7. Security:

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.

  • If you register to have an account with us, you will be asked to create a password. You must keep this password confidential and must not disclose it or share it with anyone. You will be responsible for all activities that occur under your password. If you know or suspect that someone else knows your password you should notify us immediately at the address provided at the end of this Policy. If we have reason to believe that there is likely to be a breach of security or misuse of Our Service, we may require you to change your password or we may suspend your account until your identity has been verified and the account has been satisfactorily secured.
  • Our Service may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

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.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, by ensuring at least one of the following safeguards is implemented:

  • transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • entering into specific contractual terms which have been approved by the European Commission and which give personal data the same protection as within the EEA;
  • where your data will be transferred to the US, ensuring that the third party to which we are transferring your data is part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US. This is the case of personal data transfers to Home Instead Inc. Home Instead Inc. participates in the EU-US and Swiss-US Privacy Shield Framework. They have certified with the Department of Commerce that they adhere to the Privacy Shield Principles. For further information, you can visit their Privacy Shield page.

10. Your rights:

  • Applicable Laws - We are committed to protecting your privacy, and will only use your personal information in accordance with the General Data Protection Regulation, the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003 together with any other laws applicable to the protection of personal data in force from time to time in England and Wales and any related regulations and guidance (as from time to time amended, extended, re-enacted or consolidated) and all subordinate legislation, regulations and guidance made pursuant to any of them;

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

Our Website/Platform contains links to other Websites and Services. These Websites and Services will have their own Privacy Policy and we accept no liability or responsibility for these Policies or how these might collect, store and use Your Personal Information.

12. Our Contact information

If you have any questions about Our Privacy Policy or how we treat your personal information please do not hesitate to contact us by email at: info@elunow.com.