1. Introduction

1.1

This Family Portal Privacy Policy (together with our Family Portal Terms and Conditions and any other documents referred to in it) describe how Log my Care, operated by LMC Software Limited, registered under company number 10904934, (“LMC Software Ltd.”, “we’, “us”) will process any personal data we collect from you, or which you provide to us, in the course of using the Family Portal accessible via the Log my Care App (the “Family Portal”) services to which you are granted access (the “Services”).

1.2

It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

1.3

For the purposes of the Data Protection Act 1998 (the “Act”) and EU Regulation 2016/679 – the General Data Protection Regulation in effect from 25 May 2018 (“GDPR”) we are a Data Controller. We are ICO registered with registration number ZA310961.

2. Scope of our services

2.1

Log my Care operates a platform that allows social care providers to manage the care of their clients. The Family Portal enables the family and friends of care service patients to access certain care and personal records of their relative or friend when they sign up to the Family Portal. Please note that you must be invited to join the Family Portal by a member of staff at your relative’s or friend’s care service.

2.2

This Privacy Policy applies to the Family Portal and explains how we collect and use the personal data that:

• The relevant care service stores about you and provides to us
• You provide to us when you sign up to the Family Portal.

Please note that we have separate privacy policies that govern the use of our other software and apps that allows social care providers to manage the care of their clients.

2.3

Log my Care will make this Privacy Policy available to every care service that uses the Family Portal, as it outlines how relatives’, friends’ and care service clients’ personal data will be collected and processed. Each care service is fully responsible for explaining to its clients how their data will be processed on the Family Portal.

3. The information we collect

3.1

You need to be invited to use the Family Portal by a care provider at a participating care service. In order to be invited, the care provider will provide us with the following information about you so that we can send you an invitation:

• Your full name
• Your relationship with the care service patient
• Your address
• Your telephone number
• Your email address
• The reasons for inviting you or not inviting you to join the Family Portal (if any)
• The date on which an invitation to join the Family Portal is sent to you
• If you have a power of attorney for your relative or friend and the nature of any power of attorney
• If you are a next of kin for your relative or friend.

3.2

When you access the Family Portal, there are a number of ways in which you provide, or we collect, information and other data about you. We may have access to the following personal data:

• Any visits which you make to your relative or friend in the care service.
• Any communications which you may have with us.
• Information about how you interact with the Family Portal, such as the number of times you use the Family Portal and how you navigate its features.
• Any communications, photos, videos, voice messages and calls, files, and location information which you share on the Family Portal.
• Information about your device such as your IP address, browser type, referring/exit pages, and operating system.
• Cookie data (please see our Cookie Policy for details of how we store Cookie data).

4. How your information is used

4.1

The personal data that we collect from you may be used to:

• Create your personal Log my Care profile and allow you to access your relative’s or friend’s care information.
• Enable communication between yourself, the care service and your relative or friend.
• Share communications, photos, videos, voice messages and calls, files, and location information between yourself, the care service, your relative or friend and other Family Portal users (who know your friend or relative).
• Enhance user experience and improve our Family Portal (for example, where you suggest a new feature for the Family Portal to us).
• Let you know of new features which we have made available on the Family Portal.
• Let you know about Log my Care and its business (please see Section 11).
• Respond to your questions and concerns.

5. Payment

5.1

Your payment information (including your credit or debit card details) and billing postcode may be collected and stored by Stripe or GoCardless, our third-party payment providers. We will not store, or otherwise have access to your payment information.

6. Legal bases we rely on

6.1

We rely on the following legal bases for processing your personal data:

• You have given your consent, by logging onto your profile on the Family Portal, for us to process your data so that we can provide you with updates of your family member or friend.
• Processing is necessary for our arrangement with you (for example, to provide you with updates of your relative or friend residing in a care service).
• It is in our legitimate interests (for example, operating and making the Family Portal available in order to provide care updates to you).
• It is in the care service provider’s legitimate interests (for example, to grant you access to your relative’s or friend’s wellbeing information).

7. Consequences of not providing your personal data

7.1

Your personal data is necessary for us to create your profile for you to use our App. If you do not supply your personal data to us or are not happy for us to receive your personal data from the relevant care service, then we will be unable to provide the Family Portal to you.

8. Sharing your information

8.1

Except as described below, we will not share your information with any third parties.

8.2

We may disclose the information you provide us:

• To our third-party APIs, including but not limited to Intercom and Google Analytics.
• Our third-party ID verification provider, if we need to complete ID checks on you.
• To any of our group companies (which means our subsidiaries, and our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
• To protect the rights, property, or safety of ourselves or others, as required by law under any Family Portal regulation. This may include disclosing to other companies and organisations in connection with fraud protection and credit risk reduction.
• To protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, when we believe in good faith that disclosure is necessary.
• If LMC Software Ltd. is involved in a merger, acquisition, or sale of all or a portion of its assets, to any prospective seller or buyer of all (or part of) our business or assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
• As part of a completely anonymised data set to research bodies or other organisations to perform analysis.
• To any other third party with your prior consent to do so.

8.3

We will never pass your information to a third party for them to use in their own direct marketing without your express consent.

8.4

Please note that if you click on or follow any links from the Family Portal to external websites, this Privacy Policy will no longer apply to you. Please check the privacy policies of any such external website or app before submitting any personal data, as we cannot accept any responsibility or liability in relation to them.

9. Security, data retention and storage

9.1

The security of your personal information is important to us. All information you provide to us is stored using Amazon Web Services and hosted within the European Economic Area (“EEA”).

9.2

Any payment transactions and databases will be encrypted using SSL technology and AES-256 respectively.

9.3

We will keep your personal data whilst you continue to have a profile on our Family Portal.

9.4

If you end your subscription of the Family Portal, we will delete your Family Portal account data within six (6) months, except for any of your personal data which we need to keep to comply with our legal obligations, resolve disputes and enforce our agreements.

9.5

If you request that we remove your personal data at any time, we will endeavour to delete your personal data as soon as possible, save in respect of where we need to keep your data to comply with our legal obligations, resolve disputes and enforce our agreements, or where we are otherwise allowed by law to keep your personal data.

10. International transfers

10.1

Information we collect may be transferred to, stored and/or processed in any country or territory where one or more of our partners or third-party service providers (for example, our hosting company) are located or maintain facilities, including destinations outside the EEA.

10.2

While other territories may not have the same standards of data protection as those within your home country, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

10.3

By submitting your personal data, you agree to this.

11. Contacting you

11.1

We may contact you from time to time about Log my Care, including marketing messages relating to Log my Care. We will do this electronically, for example by email, text, notifications or other messages on your mobile device, telephone or by post.

11.2

We may contact you with information about our products and services (and those of specially selected parties that may be of interest to you) in line with your marketing contact preferences provided to us either through the Family Portal or by emailing us. All such communications will come from LMC Software Limited.

11.3

You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at the email below or by following any instructions we may include in the messages we send to you.  

12. Use of location data

12.1

The Family Portal may make use of location data sent from your mobile device. You can turn off this functionality at any time by switching off the location services settings for the Family Portal on your mobile device.

12.2

If you use the Family Portal, you consent to the transmission, collection, maintenance, processing and use of your location data and queries for the purposes set out in Section 4 and to tag any content uploaded to the Family Portal with your location, by us, our partners and licensees. You may withdraw this consent at any time by turning off the location services setting on your mobile device.  

13. Syncing with other apps

13.1

Certain features of the Family Portal (such as uploading or downloading content) may need to access information or other applications on your device in order to work (e.g., your camera). By using such functionality, you consent to Log my Care accessing your device and information and you consent to this information potentially being shared with the care service provider, your friend or relative in the care service and other Family Portal users (who know your friend or relative).

13.2

If we can, we will ask you before the Family Portal accesses your device, other applications on your device or information. You may also manage how the Family Portal accesses your device or information using privacy settings on your mobile device or by uninstalling the App.

13.3

By using the Family Portal, you accept that:

• Photos will be stored in the Family Portal and not on your device.
• Other Family Portal users (who know your friend or relative), the care service provider and your friend or relative in the care service may have access to your uploaded photos.
• If you sync your camera with the Family Portal, you consent to us accessing your photos and storing the photos solely for the purposes described above. We will not collect or store any names, emails, addresses or other contact information from your device. If you do not want to use this feature or do not want your photos to be uploaded or accessed in any way, you may not use this feature of the Family Portal.  

14. Your rights

14.1

You have the general right to request from us:

• Access to your personal data
• Rectification or erasure of your personal data
• Restriction of processing concerning you or to object to our processing of your personal data
• The right to data portability.

14.2

If you wish to exercise any of these rights, please contact us by emailing support@logmycare.co.uk. You also have the right to complain to the Information Commissioner’s Office about the manner in which we process your personal data.

15. Accessibility and changes to this Privacy Policy

15.1

From time to time, we may need to update this Privacy Policy to ensure that it remains up-to-date. If we make significant changes, we will make that clear on our Family Portal or by some other means of contact, such as email, so that you are able to review the changes before you continue to use our Family Portal.

15.2

Please refer to the date at the top of the Privacy Policy to make sure that you are looking at the latest version.

15.3

The Family Portal is currently available on the Apple and Google Play App Stores. The requirements of iOS and Android devices may vary (and for any additional operating systems we decide to extend the availability of the Family Portal to) and may change, and you will need to download any necessary updates if you want to keep using the Family Portal. We do not promise to always update the Family Portal so that it is relevant to you and/or works with the iOS and Android version that you have installed on your device.

16. Contact

16.1

If you have any questions about our Privacy Policy and the data we hold on you, or you would like to exercise your data protection rights, you can contact us at support@logmycare.co.uk.