1. Our Commitment to Your Privacy

Centrim Life UK Ltdwith Company Number : 16529540 (“we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable UK data protection laws. This Privacy Policy explains how we collect, use, disclose, and protect personal data through our digital platforms and services.

2. Who This Policy Applies To

This Privacy Policy applies to personal data we process as part of our services in the care home and retirement living sectors, including data related to:

• Residents and their authorised representatives
• Care staff and employees of client organisations
• Family members, visitors, and appointed contacts
• Prospective clients and service users
• Website visitors and users of our mobile and web applications

3. What Personal Data We Collect

We may collect and process the following categories of data:

• Identity and contact information (e.g. names, email addresses, phone numbers)
• Employment-related data for authorised staff
• Location data and IP address (where permitted)
• Health and sensitive data (processed only with appropriate consent or legal basis)
• Feedback, bookings, and service-related records
• Transaction and payment details (via secure third-party providers)
• Technical and usage data (browser, device type, activity logs)
• Marketing and communication preferences

4. How We Collect Your Data

We may collect personal data:

• Directly from individuals or their representatives
• Through client organisations (e.g. care providers)
• Via our digital platforms and automated technologies
• From third-party integrations with clinical or operational systems
• Via cookies, analytics tools, or support interactions

5. Why We Use Your Personal Data

We use personal data to:

• Provide access to and operate the Centrim Life platform
• Support care delivery, resident engagement, and staff workflows
• Facilitate bookings, services, and feedback management
• Meet contractual, regulatory, and legal obligations
• Maintain service quality, security, and platform performance
• Communicate updates and service-related messages

6. Legal Bases for Processing

We rely on the following legal grounds for processing personal data:

• Consent (e.g. marketing preferences or processing sensitive health data)
• Performance of a contract (e.g. providing access to our platform)
• Legal obligations (e.g. safeguarding or compliance reporting)
• Legitimate interests (e.g. service improvement, fraud prevention)

7. Children and Vulnerable Individuals

We may process personal data of children or vulnerable individuals through their legal representatives or care providers. Appropriate safeguards and consents are ensured in accordance with applicable laws.

8. Automated Decision-Making

We do not conduct automated decision-making that has legal or similarly significant effects. Any AI or automation features are designed to assist human decision-makers, not replace them.

9. Sharing Your Personal Data

We may share your personal data with:

• Affiliated Centrim Life entities and contracted providers
• Authorised sub-processors (for hosting, support, or analytics)
• Integration partners (clinical or service platforms)
• Professional advisors (e.g. legal, accounting)
• Regulatory or enforcement bodies where legally required

We do not sell your personal data.

10. International Data Transfers

Where data is transferred outside the UK (e.g. to Australia or EU-based servers or partners), we use appropriate safeguards such as Standard Contractual Clauses (SCCs) or adequacy decisions to ensure your data remains protected in accordance with UK GDPR.

11. Use of Anonymised or Aggregated Data

We may use anonymised or aggregated data for analytics, product development, service benchmarking, and internal reporting. This data cannot be used to identify any individual.

12. Data Security

We implement industry-standard security measures, including:

• AES-256 and TLS encryption
• Role-based access controls
• Secure development and hosting practices
• Routine penetration testing
• Staff training on data protection

13. Data Retention and Deletion

We retain personal data only for as long as is necessary for the purposes outlined above or as required by law. Upon service termination or request, we will return or securely erase personal data unless legally required to retain it.

14. Your Rights

Under the UK GDPR, you have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request erasure ("right to be forgotten")
• Restrict or object to processing
• Data portability
• Withdraw consent at any time (where processing is based on consent)
• Lodge a complaint with the Information Commissioner's Office (ICO)

15. Cookies and Third-Party Links

We use cookies and similar technologies to optimise your experience. Our services may link to third-party websites; we are not responsible for the privacy practices of those external platforms.

You can manage cookie preferences through your browser settings or within our platform's cookie banner.

16. Contact and Complaints

If you have any questions about this policy or our privacy practices, please contact:

Privacy Officer
Centrim Life Ltd
Email: privacy@centrimlife.co.uk
Website: www.centrimlife.co.uk
Phone: +44 1604 279636
Address: Victory House, Business Park, 400 Pavilion Dr, Northampton NN4 7PA, United Kingdom

If you are not satisfied with our response, you may contact the UK Information Commissioner's Office:
Website: https://ico.org.uk

17. Updates to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via our platform or email. Please review this page regularly to stay informed of any updates.