We keep our privacy notice under regular review. This version was last updated on 26/10/2023. Click here to read the previous version of this privacy notice.
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:
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 email@example.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.
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:
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.
We use different methods to collect data from and about you including through:
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:
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To manage our relationship with you which will include:|
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods that may be of interest to you||(a) Identity|
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
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.
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.
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.
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.
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:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not transfer your personal data outside the United Kingdom.
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.
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.
We do not undertake any automated decision making or profiling in relation to your personal data.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
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.
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 firstname.lastname@example.org.
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.
We encourage you to contact us at email@example.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.