For the purposes of applicable data protection laws, the data controller is Access Your Right To Care, a charitable company registered under the Charities Act 2011 (registration number 1186714) whose registered office is located at Oakwood House, St Patrick’s Road, Coventry, CV1 2HL.

This Privacy Notice covers all personal information collected and used by us in the context of the following categories of individuals:

·        Chatbot users

In this Privacy Notice, "personal data" or "personal information" means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly. See more detail below on the personal data we process (i.e., collect, store, access, etc.) about you.

We use the personal information we collect from and about you for a variety of purposes and based on one or more legal justifications, as set out below.

Data categories

·        Forename, surname, email address, telephone number

·        Any other personal information that you provide us in relation to your circumstances

Purposes of processing

·        To assist us to converse with you during a chatbot conversation

·        To complete a template letter for you to use

·        To send you a transcript of your chatbot conversation

·        To send you a follow up email within 14 days

Lawful basis

·        Legitimate interest in effectively communicating with you to pursue our charitable goal of supporting people with social care needs, which is in the interests of society at large.

Data categories

·        Special categories of personal data relating to your social care needs (e.g., disability status, religion, ethnicity and health data)

·        Your local authority area

Purposes of processing

·        To complete a template letter for you to use

·        To better understand the needs of our stakeholders

Lawful basis

·        Your explicit consent

Our legitimate interest in learning more about our stakeholders' needs as part of our charitable goal of supporting people with social care needs, which is in the interests of society at large. 

We may share your personal information with the following third party organisations:

Our service providers. We use other companies or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of the ASC services and products to you. We may share personal information with the following categories of Service Provider:

·        Infrastructure and IT service providers (including for secure file storage and destruction services, cloud storage services); and

·        Our technical partners who develop the chatbot infrastructure (including for quality and compliance audits).

In the course of providing such services, these Service Providers may have access to your personal information. However, we will only provide our Service Providers with the information that is necessary for them to perform the services, and we ask them not to use your information for any other purpose. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.

Third parties permitted by law. In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies or to judicial or administrative authorities). We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our Terms and Conditions or protect your rights or those of the public.

Your data is stored and processed within the UK, the EEA and the USA.

In the event that your personal data is transferred to, and stored at, a destination outside the European Economic Area ("EEA") (including transfers to the USA), we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal information.

You have various rights in connection with our processing of your personal information, each of which is explained below.

·        Access. You have the right to request a copy of the personal information we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information.

·        Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.

·        Deletion. You have the right to request that we delete personal information that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

·        Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. In such case, we would mark stored personal information with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.

·        Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent (such as for direct marketing communications) or to perform a contract with you (such as to manage your online account).

·        Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.

·        Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. If you would like to withdraw consent, including if you would like to opt out of receiving marketing correspondence from us, please contact us at enquiries@accesscharity.org.uk or for marketing follow the unsubscribe instructions located in the email (as relevant). Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your online account, relationship, activities, transactions and communications with us. Additionally, if you do request that we stop sharing your personal information with third parties for their direct marketing purposes, it is also prudent you opt out from or contact that third party directly.

·        Make a complaint. You have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.

If you wish to exercise one or more of the above rights, please contact us with your request at enquiries@accesscharity.org.uk, and include your name, email and postal address, as well as your specific request and any other information we may need in order to provide or otherwise process your request.

If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:

Telephone: +44 0303 123 1113 Email: casework@ico.org.uk Website: www.ico.org.uk Web-form: www.ico.org.uk/concerns/ Address: Water Lane, Wycliffe House, Wilmslow, Cheshire, SK9 5AF

If you are based or the issue you would like to complain about took place elsewhere in the European Economic Area (EEA), please click here for a list of local data protection authorities in the countries within the EEA in which we operate.

Note that the rights outlined above only extend to personal information.

We will only retain your personal data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. For chatbot user data this is normally for 14 days after your chatbot conversation.

When we no longer need to use your information, we will remove it from our systems and records and / or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

We have implemented technical and organisational security measures in an effort to safeguard personal information in our custody and control. Such measures we have implemented include, limiting access to personal information only to employees and authorised Service Providers who need to know such information for the purposes described in this Privacy Notice, as well as other technical, administrative and physical safeguards.

While we endeavour to always protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

We use cookies to collect information about your use of our website. A cookie is a small file that is stored on your hard drive. When you use a website, the browser checks for any cookies to decide how best to display the website to you. You have the option of declining to allow the use of cookies when you first visit our website. You can read about the cookies that we use on our website here.

Changes to this Privacy Notice

This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.

We reserve the right to change our Privacy Notice from time to time. If we decide to change our Privacy Notice we will notify you of these changes via email and post an alert on the home page of our global website.

If you have any questions about this Privacy Notice and/or about the privacy policies and practices of our service providers, please contact us at enquiries@accesscharity.org.uk, or at: Oakwood House, St Patrick’s Road, Coventry, CV1 2HL.

© Access Charity - Registered 1186714