CareFynd’s mission is to help you find care easily. To do so, we need personal information from you and for the people you are looking to find care for – there’s no way around it. But we don’t take this responsibility lightly. We recognise the importance of privacy and your rights, and we want you to feel confident about using our services and in your interactions with us. We want you to love CareFynd as much as we do, but if you do not agree with this policy then please do not access or use the Websites.

The sections below contain the information you may want to know about this topic. We’ve tried to make them as straightforward as possible, but we realise it’s a lot of information. If you still have any questions, please reach out to us via any of the contact methods listed at the end of this Policy.

This Privacy Policy describes how CareFynd Ltd collect, use, and disclose your Personal Data. Throughout this document, we will use a few definitions to describe various products, roles and relevant terms:

• “We/Our/Us” means CareFynd Ltd, carefynd.com and carefynd.co.uk
• “Websites” means all of the text, data, information, software, graphics, photographs and more that we and our Care Providers may make available to you, plus our websites and any services, extensions, plug-ins, software, or applications that we may provide to you
• “Fynders” or “Users” are the people who have created a CareFynd account to look for care (can also be a Resident)
• “Residents” are the people who are looking to be placed within a Care Home with a Care Provider (can also be a Fynder)
• “Care Providers” or “Partners” are the Care Homes registered with the Care Quality Commission (CQC) who we are contacting on your behalf to facilitate the placement of the Resident
• “Placing/Placement” means the successful acceptance of the Resident by the Care Provider within their Home
• “Home” means the premises or any location under the responsibility of a Care Home
• “Personal Data” is any data relating to an identified or identifiable natural person that is processed by CareFynd as described in this Privacy Policy when such information is protected as “personal data” or “personal information” or a similar term under applicable data protection laws
• “GDPR” means the General Data Protection Regulations
• “Act” means the Data Protection Act 2018
• “Policy” means CareFynd’s Privacy Policy
• “Cookie Policy” means CareFynd’s Cookie Policy

carefynd.com and carefynd.co.uk provide an online service owned and operated by CareFynd Ltd. Please take the time to review this Policy which explains the information that CareFynd collects about you, how we use it, and your rights in relation to that information.

For the purpose of the Data Protection Act 2018, CareFynd Ltd (registered in England & Wales with Company number: 13588920) of 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ, United Kingdom is the data controller of the personal information collected via or in connection with our websites (carefynd.com and carefynd.co.uk). On 25th May 2018, the Act was superseded by the General Data Protection Regulation. The terms of this Policy are applicable under the Act and GDPR.

Under the GDPR, the lawful basis upon which we process your personal data is that such processing is necessary for your legitimate interests and necessary for us to provide the services under our contract with you.

We collect personal information from you when you provide it to us directly and through your use of the websites. This information may include:

• Information you provide to us when you create an account with us, which will include your name, email address, postcode and password;
• Information you provide when using the websites, for example your telephone number, searches, IP address, reviews and comments;
• Information you provide when you are looking to search for suitable Care Providers for the Resident’s needs, for example details of the Resident and how to contact you;
• Any correspondence you have with Care Providers via our websites;
• Records of your interactions with CareFynd (e.g. if you contact our support team). We maintain a record of and recordings of certain telephone calls to and from CareFynd made in connection with the CareFynd service for quality control and training purposes;
• Information you provide to us when you enter a competition or participate in a survey; and
• Information collected automatically, using cookies and other tracking technologies (e.g. which pages you viewed and whether you clicked on a link in one of our email updates). We may also collect information about the device you use to access our websites, your IP address (which may allow us to see your geographical location) and your browser or operating system type and version.

We may also receive confirmation from our Care Providers if you agree to the Resident’s stay at their Home having had contact through our websites, for our accounting purposes and to manage the Care Provider’s account with us.

This Policy is primarily aimed at the users (Fynders) of our websites. However, if you work for a Care Provider with whom we partner or are applying for a job with CareFynd, please read the below.

If you work for a Care Provider with whom we partner, we will collect your business contact details such as name, email address, job title and telephone numbers as well as other information relevant to our professional relationship with you, which may include a photo to display on the websites. We will also maintain a record of your communications with us and with Users via our websites.

We may collect information about you from you directly, from your employer, from a User of our websites, or from publicly available sources (e.g. your websites).

We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes and for quality control purposes.

We will use this information for the purposes of developing and maintaining our partnership with you. If you would like to update or delete your Care Provider details on our websites, please contact us.

We maintain a record of and recordings of telephone calls to and from you for quality control and training purposes.

We can share your email address and phone number with Users/Partners of the websites to facilitate you placing a Resident requiring care.

If you apply for a job with CareFynd, we will collect and use the information you provide to us in the course of your application to assess your suitability for the position you have applied for and for other roles in the future, and to monitor diversity and equal opportunities within our recruitment process. Please note that as part of the application process, we may also collect information about you from third parties, for example recruiters, referees, or from publicly available sources (e.g. LinkedIn). Please visit our websites for more information about careers at CareFynd, or contact us (see below).

Depending on how you use our websites, your interactions with us, and the permissions you give us, the purposes for which we use your personal information include:

• To fulfil requests submitted via the websites and maintain your online account;
• To contact you about your use of the websites and send you Care Provider offers;
• To show the details of the Resident to potential Care Providers and to enable potential Care Providers to make you an offer to place the Resident;
• When you contact a Care Provider via our websites, CareFynd (or its service provider) may telephone you or message you to confirm whether you placed a Resident with that Care Provider. This telephone call may be recorded for training and quality control purposes;
• To assist you and the Care Provider to complete the placing of the Resident;
• To manage and respond to any queries or complaints to our customer service team;
• To personalise the websites to you and show you content we think you will be most interested in, based on your account information and your history on the websites;
• To fulfil our obligations to the Care Providers we work with;
• To improve and maintain the websites, and monitor its usage;
• For market research, e.g. we may contact you for feedback about your experience on our websites;
• To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so;
• For security purposes, to investigate fraud and where necessary to protect ourselves and third parties;
• To comply with our legal and regulatory obligations; and
• To share the data we collect about you with brands and retailers (see Marketing & Advertising below), where we have your consent or have a legitimate interest to do so.

Under the GDPR, the lawful basis upon which we process your personal data is that such processing is necessary for your legitimate interests and necessary for us to provide the services under our contract with you, for example, when you subscribe to receive emails from us, search Care Providers, register the details of the Resident looking for care via our websites. You can withdraw your consent at any time, such as by unsubscribing for our service or contacting us, making it clear that it is for a Withdrawal of Consent.

Further examples of processing your personal information where it is in our legitimate interests to do so, in order to maintain our websites and conduct our business are:

• We conduct an analysis on our user base and the searches made via our websites;
• We (or our service provider) may contact you after you have used our websites to ask if you have placed a Resident with a Care Provider (so that we can collect commission from the relevant Care Provider, and for our own internal research purposes); and
• Where you or a Care Provider confirm that you have placed a Resident via the websites, we will process your personal information in order to fulfil our obligations to the Care Providers we work with and collect any commission due.
• Where you work for a Care Provider to monitor and record our and customers communications with you for the purposes set out in the paragraph above.

We love to communicate with our Users and so, depending on your marketing preferences, we may use your personal information to send you marketing, including by email, SMS or post. Some of these messages may be tailored to you, based on your previous use of our websites.

If you no longer want to receive communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us via the details at the bottom of this Policy. If you unsubscribe please note we will still contact you with transactional messages from time to time, including to send you offers from Care Providers in response to a request you make on the websites.

You may see adverts on our websites and also see adverts for our websites on third party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to Fynders/Users who have visited our websites) and/or similar technologies or using information that you provide to us through your online account. Where you see an ad on third party websites, our websites or social media, this may be because we have engaged the third party or social network to show ads to our Fynders/Users, or others who match the demographic profile of our Fynders/Users. In some cases, this may involve sharing your email address, postcode or other unique identifiers (such as a cookie ID) with the third party (such as Google) or social network (which includes Facebook) so that they can identify you as one of our Fynders/Users and serve you with an advert. If you no longer want to see tailored ads you can change your cookie settings on our websites - please see our Cookie Policy for further information about the cookies we use.

When you use our websites, we may from time to time share information about this via a unique identifier which relates to you or sharing your hashed email address and/or User ID with certain third parties (for example digital optimisation providers) with whom we partner from time to time. Certain third parties will use this information to verify if you have previously consented to receive email marketing from them (or where they are otherwise legally permitted to send you marketing), and if so, so they can personalise their marketing to you accordingly. Please note that the marketing you receive from any such third parties is subject to the privacy notices/policies and practices of the relevant third party and not CareFynd. If you have any concerns about any marketing you receive from any third party Care Provider (or other third party advertiser), you should contact the relevant third party.

We may also share your data with brands and service providers who will match it with data that they receive about you from other sources for tracking, digital optimisation, targeted advertising and email marketing purposes.

We share Fynders/Users’ personal information with third parties in the following circumstances:

• Where you are negotiating to place a Resident with a Care Provider, to pass on your interest or specific query. Please note, however, that CareFynd does not share your full contact details with Care Providers for contact purposes except for Resident vacancy enquiries where you have specifically requested the Care Provider contact you and you provided your details (Care Providers will use your details in accordance with their Privacy Policy). Save where the exceptions apply, the only information which they can receive from us is your name and postcode, as well as any information you choose to share via our messaging tool or which you provide as part of enquiry request for vacancy within their Home. On occasion we may share your email address with Care Providers for the purpose of confirming that a particular agreement was made through the websites. Where you agree to place a Resident with a Care Provider we refer you to, this Care Provider may let CareFynd know that you have agreed to place a Resident as a result of our referral (this way we can track how useful our websites have been to customers);
• If you want to promote details of a Resident looking for care, we’ll share the Resident’s details you’ve given us, along with an approximate location, with Care Providers. If a Care Provider indicates interest in the ability to place the Resident which you accept, we’ll give them your name, email and/or phone number so they can contact you as well as details about the Resident. Care Providers are likely to call/message you about their interest.
• CareFynd may text you with details of offers of interest where you provide your number.
• With our Care Providers, for example we may use a service provider from time to time to contact you via telephone to confirm whether you successfully placed a Resident via our websites or to assist with the placing of the Resident;
• With third parties for direct marketing and targeted advertising purposes (see Marketing & Advertising above);
• With our professional and legal advisors;
• With third parties engaged in fraud prevention and detection;
• With law enforcement or other governmental authorities, in response to a lawful request or court order;
• Otherwise where we have your consent or are otherwise legally permitted to do so.
• We also disclose aggregate data, which does not identify any Fynders/User personally, including to third parties working in media, consumer research and the care industry (for example, as analysis of Residents placed in care in a given year).

Our websites are hosted by Amazon Web Services, and any personal data we collect from you through our websites may be transferred to, and stored at, a destination within the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy and our Cookie Policy.

All information you provide to us is stored on Amazon Web Services secure servers.

Unfortunately, the transmission of data via the internet is not completely secure. Although we will take all reasonable endeavours to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, please be assured that we will use strict procedures and security features to try to prevent unauthorised access to, destruction of or damage to such personal data..

If you would like to delete your account with CareFynd, please contact us using the details below. Please note, however, that if you delete your account we may retain some of your details (for example if you have made a complaint about our websites), for as long as is necessary to protect us from a legal claim. If you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

Our websites are not intended for, and should not be used by, anyone under the age of 18. We do not knowingly collect personal information from individuals under 18.

Our websites use cookies and similar technologies to provide certain functionality to the websites, to understand and measure its performance, and to deliver targeted advertising. Please see our Cookie Policy for further information about the cookies we use and how to amend your cookie settings.

You have certain rights in respect of your personal information, including the right to access, correct, and request the erasure of your personal information.

You also have the right to object to your personal information being used for certain purposes, including to send you marketing. See ‘Marketing’ above, for more details of how to opt-out of marketing.

We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal information, or if you have any questions or concerns regarding your personal information, please contact us using the details below. You are also entitled to contact the UK’s supervisory authority for data protection, the Information Commissioner’s Office, or your local supervisory authority.

If you have any queries on any aspect of our Privacy Policy or want to close your account, please contact us by email at info@carefynd.com or by post at the address below.