Privacy Policy

We are committed to being transparent about what data we collect from you and how we will use it. This privacy policy is designed to help you feel more confident about the privacy and security of your information when using (1) any device we provide to you; (2) uploading or inputting data from medical devices not provided by us; and (3) adding data and information to your online account accessed via our website www.carosconnect.com.

The “Service” is an online platform which allows you to gather, edit, store and share your health information (your “Caros Account”). You can also choose to share this information with friends, family and healthcare professionals.

This privacy policy (together with our terms of service) sets out the basis on which we process any personal information we collect from you, or that you provide to us through the Service.  Your information includes sensitive personal data. By using the Service and signing our Terms you expressly agree that we may process your sensitive personal data in accordance with this privacy policy.

If you have any questions or suggestions regarding our privacy policy, please contact us at: info@carosconnect.com.

The terms “Company”/”we”/”our”/”us” when used in this Privacy Policy means Caros Connect Limited, and “you”/”your” means you as a user of our Service.

1. AGE REQUIREMENTS

Individuals under the age of 18 are not permitted to use the Service. As such, we do not knowingly collect personal information from people under 18 years of age. If you are under 18 years old, please do not provide any personal information to us.

2. INFORMATION WE MAY COLLECT ABOUT YOU

2.1      We may collect and process the following personal information (including sensitive personal data) about you:

2.1.1      health readings you record on devices (eg: your blood pressure, activity levels and weight) provided to you by Caros in connection with the Service; health readings and information you upload to your on-line profile from other sources

2.1.2      information that you provide when registering or for or using our Service (such as your name, email address and date of birth, or any medical history you upload to your Caros Account);

2.1.3      [information that you authorise a third party (e.g. a social network such as Facebook) to share with us, such as your email address or other information that may identify you;]

2.1.4      correspondence, or a record of it, if you should contact us; and

2.1.5      surveys that you complete.

2.2          We will also collect statistical data about your browsing actions and patterns, which does not identify you.  This means information about your computer and your use of our Services, including (where available) your IP address, unique mobile device identifier (UDID), International Mobile Equipment ID (IMEI), Android ID, device MAC address, browser information, operating system, timestamps, the pages that you request, applications downloaded, traffic data, location data, weblogs and other communication data, and the resources that you access.

3. HOW WE USE YOUR INFORMATION

3.1          We use your personal information in the following ways:

3.1.1      to provide you with the Service;

3.1.2      to monitor your use of the Service and send you offers (eg: shopping vouchers or other rewards)  to induce you to submit regular and accurate health readings;

3.1.3      to ensure that the Service is presented in the most effective manner for you and for your computer;

3.1.4      to identify you when you use the Service;

3.1.5      to answer your questions and improve the Service;

3.1.6      to notify you about changes to our Service; and

3.1.7     to provide you with updates and other information about special offers and new features of our Service.

3.1.8      to create an anonymised, aggregated dataset. The anonymization is done by replacing names with random serial numbers, and removing other sensitive personal information (address, date of birth). This anonymised data is then aggregated and analysed to generate new insights to help the creation of better (or new) products and services to benefit society.

4. HOW WE SHARE YOUR INFORMATION

4.1          We may share your personal information (including your sensitive information) with third parties in the following circumstances:

4.1.1      with individuals that you invite to your Care Network (these individuals are known as your “Supporters”) eg: your family, friends, doctor etc). By issuing invitations to these individuals to join your Care Network you give Caros express permission to share all information and data stored in the profile with them. They will see all of the information that you have uploaded to your Caros on-line profile.  Some of this information may be highly sensitive, so please consider carefully who you wish to share it with. You may remove individuals from your Care Network at any time so that they may no longer view your personal information.

4.1.2      with our partners and service providers for the purpose of managing or administering certain aspects of our Service;

4.1.3      to protect the rights, property or safety of us or other Service users;

4.1.4      where we are obliged, or permitted, to do so by law; or

4.1.5      if we (or substantially all of our assets) are acquired by a third party, in which case personal information held by us about our users will be one of the transferred assets.

4.2          We may hire other companies to provide limited services on our behalf, such as a customer service phone line. We give these companies only the personal information they need to deliver the service, such as an IP or email address. We do not make the data in your on-line profile (such as your readings) available to these other companies.

4.3          We may pass aggregated information to third parties about how our users use our Service but this will not include information which could be used to identify you.

5. WHERE WE STORE YOUR INFORMATION

5.1          We take appropriate organizational and technical measures to protect the personal information that we hold.  We limit access to your personal information to those who we believe reasonably need to come into contact with that information in order to carry out their jobs.

5.2          The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA).  It may also be processed by staff operating outside the EEA who work for us, one of our associated companies or a third party engaged by us.  By submitting your personal information to us, you agree to such transfer, storing or processing.  We will take all steps reasonably necessary to ensure that your personal information is treated securely at all times and in accordance with this Privacy Policy.

5.3          Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Service and any transmission is at your own risk.

5.4          When your agreement with us comes to an end your Caros Account will be closed and your personal information permanently deleted within 90 days of closing. We will retain your information for as long as is necessary to fulfill any of the services we provide or to comply with applicable legislation, regulatory requests and relevant orders from competent courts.

6. COOKIES

6.1          We use cookies and similar technologies such as local storage within our apps to provide and optimise our Service. You can control which cookies you get and which you keep on your device through your browser settings.  Unless you have adjusted your browser settings so that it will refuse our cookies, our system will issue cookies when you visit our website. However, if you do not accept cookies you may not be able to take advantage of many of the special features of the Service.

6.2          We use cookies to keep track of the pages you and other visitors have been to on our Service, including serving advertisements which we believe are most likely to be of interest to you.

6.3          All of the major browsers offer tips and guidance for managing the cookies available on your browser.  There are also lots of different third party browser plug ins and extensions available which you can download to make it easier to see and control your cookies.

6.4          You can find out more about internet advertising by visiting the following websites: www.allaboutcookies.orgwww.yourchoicesonline.eu, and www.networkadvertising.org.  Some of these sites enable you to opt out of online behavioural advertising and other tracking cookies (in addition to the control settings on your browser).

7. LINKS

Our Service may contain links to and from other websites and services. We are not responsible for the privacy practices or the content of any third party sites.  Please check the individual privacy policy of any such websites or services before you submit any personal information to them.

8. ADVERTISERS

We may from time to time use third party advertisers or sponsors on our Service.  In the event that we do so we will not disclose identifiable information about individuals but we may provide them with aggregated information about our users.  We may also use such aggregated information to help advertisers reach the kind of audience they want to target (for example, men in London). We may make use of the personal information we have collected from you to enable us to comply with our advertisers’ and sponsors’ wishes by displaying their advertisement to that target audience.

9. YOUR RIGHTS

You have the right to ask us not to process your personal information for marketing purposes. We will inform you, before collecting your personal information, if we intend to use your personal information for such purposes or if we intend to disclose your personal information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms or registration pages we use to collect your information. You can also exercise the right at any time by contacting us by post or email at the address set out below.

10. ACCESS TO INFORMATION

You have the right to access information held about you. Your right of access can be exercised in accordance with UK data protection laws.  Any access request may be subject to a small administrative fee to meet our costs in providing you with details of the information we hold about you.  Contact us at: support@carosconnect.com for details.

11. CHANGES TO OUR PRIVACY POLICY

We occasionally modify our privacy policy and any changes we may make to it in the future will be posted on this page and, where appropriate, notified to you by e-mail or other message.