Intelligent Lilli Limited – Privacy Notice

We keep our privacy notice under regular review. This version was last updated on 11/03/2024. Click here to read the previous version of this privacy notice.

Contents

1. Important Information About Intelligent Lilli Limited
2. The data we collect about you
3. How is your Personal Data Collected
4. How we use your personal data
   1. Marketing
   2. Marketing and Opt-Out
   3. Cookies
   4. Change of purpose
5. Service User Data
6. Disclosures of your personal data
7. International transfers
8. Data Security
9. Data Retention
   1. How long will you use my personal data?
10. Automated Decision Making or Profiling
11. Your legal rights
    1. What we may need from you
    2. Time limit to respond
12. Links to other Websites
13. How to make a Complaint
14. Changes to this Privacy Notice

1. Important Information About Intelligent Lilli Limited

Your privacy is important to us, and so is being transparent about how we collect, use and share information about you. Therefore, this privacy notice is intended to help you understand and will explain how your personal information is collected, used and shared by Intelligent Lilli Limited.

Intelligent Lilli Limited (referred to in this notice as “we”,“us” or “our”) is registered in England and Wales under company number 08832088. Our registered office is at 17k Solent House, Lansbury Estate, Guildford Road, Knaphill, Woking, England, GU21 2EP.

We are registered with the Information Commissioner’s Office (ICO) and our registration number is ZA154221.

We process your personal data in one of two designations:

1. in instances where we decide how and why your personal data is processed, we are a data controller over such data. This includes certain personal data we collect about you through your use of intelligentlilli.com (“Website”), via app.intelligentlilli.com (“Web App”) and the Intelligent Lilli mobile application (“Mobile App”). The relevant details and your rights in relation to such personal data are outlined in all sections of this privacy notice except section 5.
2. where we process your personal data under the instructions of our customer (i.e. your care provider) in connection with the services and software platform we provide to that customer (including through use of sensors installed in your home and via the Web App or the Mobile App), we are a data processor in relation to such personal data. The relevant details of such personal data are outlined in section 5 of this privacy notice and are provided for information only. The primary responsibility to comply with the regulatory obligations (including the exercise of your legal rights) in relation to such personal data lies with the data controller, which is our customer and your care provider, and you should contact them for more information and in order to exercise your rights in relation to this processing.

Please read this privacy notice carefully. Our products and services are not intended for children. We do not knowingly collect data relating to children nor do we sell our products to children.

If you have any questions about this privacy notice, including any requests to exercise your legal rights in relation to personal data for which we are the data controller (please see Section 9 below) or contact our Data Protection Officer. Our Data Protection Officer is 8fold Governance Ltd (company registration number 12085647) and can be contacted at dpo@intelligentlilli.com.

The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:

• Identity Data includes first name, last name, username, title, job title, employer name, date of birth.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• 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 our services.
• Usage Data includes information about how you use our service.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products). In this case, we may have to cancel your order.

3. How is your Personal Data Collected

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Create an account on the Web App or the Mobile App or provide information via our Website;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey;
  • Give us feedback or contact us; or
  • Request customer support.
• Automated technologies or interactions. As you interact with our service, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
  • Technical Data from analytics providers such as Google;
  • Identity, Contact, Financial and Transaction Data from providers of technical, payment and delivery and related services;
  • Identity and Contact Data from data brokers or aggregators;
  • Identity and Contact Data from publicly available sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal obligation.

You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Marketing and Opt-Out

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us (see our Contact Details at Section 1 above). Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. Please note that some parts of the Website may become inaccessible or not function properly if you disable or refuse cookies. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Service User Data

Where you are the end user of care services provided by one of our customers through use of our service (made up of sensors / smart devices we provide, the Web App and / or the Mobile App) (“Service User”), we may process personal data about you as a data processor on behalf of our customer, your care provider. This data may include Identity Data. In addition, our smart devices collect data from sensors installed in your home such as temperature, motion, humidity etc. which we make available to the Service User, carers employed or engaged by our customers (the Service User’s care provider) and the Service User’s authorised family members (together, the “Authorised User Group”). Through analysis of the streams of sensor data we may be able to determine when there are significant deviations from expected values, and notify the Authorised User Group. In some instances, the analysis of the sensor data may enable us and the Authorised User Group to infer personal data regarding your health.

You may view and amend your Authorised User Group on the “Device Info” page of the Web App and Mobile App. The processing of all information on behalf of our customers in relation to Service Users takes places entirely in the UK, by our UK staff. Only your care provider, the Service User and the Authorised User Group have access to this information.

To exercise your data protection rights in relation to such personal data and for more information on the particulars of processing, please contact your care provider (the data controller) directly.

6. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table at section 4 above – Purposes for which we will use your personal data:

• Service providers based in the United Kingdom provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide professional services.
• HM Revenue & Customs, regulators and other authorities in the United Kingdom.
• Third parties with whom we work in the course of providing the Services and carrying out ancillary activities, such as product/order packers and despatchers, mailing houses, banks and card and other payment service providers, market researchers, fraud prevention agencies and services that allow us to debug problems on our site and services.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

We do not transfer your personal data outside the United Kingdom.

7. Data Security

We have put in place appropriate organisational and technical security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you use my personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. Automated Decision Making or Profiling

We do not undertake any automated decision making or profiling in relation to your personal data.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data: (1) If you want us to establish the data’s accuracy; (2) Where our use of the data is unlawful but you do not want us to erase it; (3) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (4) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

In order to exercise any of these rights you should contact our Data Protection Officer by emailing dpo@intelligentlilli.com.

11. Links to other Websites

The Website, the Mobile App and the Web App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. This privacy notice applies only to the Website, the Web App and the Mobile App so when you visit other websites please read their privacy notices, as we cannot accept any responsibility for breaches or issues you may have in relation to data privacy on other websites or applications, including your care provider’s.

12. How to make a Complaint

We encourage you to contact us at dpo@intelligentlilli.com if you think that any collection or use of your personal data by us is unfair, misleading or inappropriate. If you make a complaint to us and think we have not dealt with it to your satisfaction, you have the right to make a complaint to the supervisory authority here.

13. Changes to this Privacy Notice