Privacy Notice

1. Background

LifeCare Residences Limited (Company Number: 05110137) and its subsidiaries, (Battersea Place Retirement Village and Grove Place Village Limited) are committed to protecting the privacy and security of the personal information you provide to us. This Privacy Notice is issued on behalf of LifeCare Residences and its subsidiaries. Where this Policy refers to “LifeCare Residences”, “we”, “us” or “our”, we are referring to the relevant company in the group responsible for processing your data. LifeCare Residences is the data controller and responsible for this website.

This Privacy Notice explains how we collect, use and protect your data when you visit our website including any data you may provide to us when you register your interest in a development, sign up for our mailing list, request a brochure from our website or provide services to us.

By browsing and using this website or providing us with any personal information you are consenting to us processing that data and agree to this Privacy Notice governing our use of it.

If you have any queries about this policy or you are unsatisfied with the way that your data has been processed in the first instance, please get in touch with the Support Office team using the contact details below: Email address: [email protected]

Postal address: LifeCare Residences, 73 Albert Bridge Road, London, SW11 4DS

Telephone: 020 7935 0075

Please note that we have separate Privacy Notices for:
• Residents and Prospective Residents of our Villages and Nursing Homes
• Prospective Employees, Workers and Contractors
• Employees, Workers and Contractors

2. Important information

Changes to this Privacy Notice and your details

From time to time, we may change or update the terms of this Privacy Notice. We recommend you regularly review this page or contact us if you have any questions regarding this Privacy Notice.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Please note our website may include links to other websites which are not owned or managed by us. LifeCare Residences is not associated with these third-party websites which may allow third parties to collect or share data about you. We cannot guarantee the privacy of any information that may be obtained by those third parties, and we therefore strongly encourage you to read the privacy policies of any website you visit before supplying information through that website. However, where third parties process data on behalf of LifeCare

Residences, we will ensure that they take appropriate measures to maintain LifeCare Residences’ commitment to protecting your data.

3. What data do we collect about you?

“Personal data”, or “personal information”, means any information about an individual that does or can be used to identify them. It does not include data where the identity has been removed (anonymous data). “Special category data” is sensitive personal data which requires a higher level of protection (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data). We do not routinely collect or request any special category data about you through our website. However, any special category data you choose to provide us with will be processed in accordance with the data protection laws.

We have categorised below the type of personal data which we may collect, use and store:

Contact information	Includes first name, surname, maiden name, marital status, title, date of birth, home address, telephone numbers, email addresses, details of relatives or primary advisers (where relevant).
IT data	Includes internet protocol (IP) address, browser type and devices used.
Information about your preferences	Includes details of your interests, preferences, feedback, and survey responses.
Usage data	Includes information about your browsing activity, the pages you visit and how you use our website and services.
Marketing and communication data	Includes your preferences for receiving marketing from us and third parties that we engage with as well as your communication preferences.

4. How is your personal data collected?

You may provide us with personal data when you:

• enquire about one of our Villages or developments via the website, by telephone, post or email;
• attend an open day or event which we attend;
• arrange a property viewing;
• subscribe to our mailing list, newsletter or other marketing communications or request a brochure;
• agree to provide us with services;
• enter a promotion or survey;
• provide feedback; and
• submit a CV or recruitment enquiry via our website.

We may receive personal data about you from various third parties and publicly available sources as set out below:

• IT Data from analytics providers;
• Information to identify and contact you from publicly available sources;
• Contact information from telephone tracking services;
• Partners that collected your details for the purpose of third-party direct marketing;
• Information to identify and contact you from events which we have sponsored and/or attended;
• Information to identify and contact you from estate agents and/or resident referrals; and
• Health professionals.

5. Cookies

A cookie is a small text file that is downloaded onto a computer or smartphone when you access a website. It allows the website to recognise your device and store some information about your preferences or past actions. We may collect IT Data automatically as you interact with our website. We collect this data by using cookies and other similar technologies. Necessary cookies are used to ensure that the website functions properly, this type of cookie does not collect any data. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. All cookies used by and on our website are used in accordance with current cookie law.

6. How do we use your personal data?

We will only use your personal information as permitted by the UK General Data Protection Regulation (UK GDPR) and any other relevant data protection laws. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract, we have entered into with you.
• Where we need to comply with a legal or regulatory obligation.
• 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.

We may also use your personal information in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest.

You have the right to withdraw consent to marketing at any time by contacting us or unsubscribing to any marketing information sent to you.

7. Purposes for which we will use your personal data

We have set out below, a description of all the ways that we might use your personal data, and which of the legal basis we rely on to do so.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

Purpose	Type of data	Lawful basis for processing
To add you to our database and/or mailing list	Contact information	(a) Consent (b) Necessary for legitimate Interest (to ensure that interested parties are kept up to date with relevant information about our products and services)
To manage our relationship with you which will include: (a) Notifying you about important changes or developments (b) Asking you to provide feedback and respond to surveys etc. (c) Inviting you to events / send you newsletters	Contact information Information about your preferences Marketing and Communication data	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how residents use our products/ services) (c) Consent
To respond to specific requests for information about services and other enquiries and to progress your interest in our services	Contact information Marketing and Communication data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (c) Consent (where appropriate)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance and reporting)	Contact Information IT data	(a) Necessary for our legitimate interests (provision of administration and IT services, to prevent fraud and protect network security) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you	Contact information IT data Information about your preferences Usage data Marketing and Communication data	(a) Necessary for our legitimate interests (to understand how residents and prospective residents use our products/services and so that we can improve, support and develop those services) (b) Consent
To improve our website, products/services, marketing, residents relationships and experiences using data analytics	IT data Usage data	Necessary for our legitimate interests (to improve user experience, to identify prospective residents, to keep our website updated and for training and quality purposes)
To make suggestions and recommendations about other goods or services that may be of interest to you	Contact information IT data Information about your preferences Usage data	(a) Consent (b) Necessary for our legitimate interests (to develop our products/services and grow our business)

8. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you wish to update the nature of your consent or your communication preferences, please contact us.

You will receive marketing communications from us if you have provided us with your specific and informed consent to receiving such marketing and, in each case, you have not opted out of receiving that marketing.

9. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by emailing [email protected] or by clicking on the link to unsubscribe in any email alerts sent to you.

10. 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 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.

11. Sharing your personal data

We may have to share your data with third parties, including third-party service providers and other entities in our group for the purposes set out in the table above. We require third parties to respect the security of your data and to treat it in accordance with applicable data protection law.

We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.

The following third-party service providers may process personal information about you for the following purposes:

• Marketing agencies/consultants – for the purposes of marketing campaigns and/or market research.
o to find other people like you to offer our products and services to.
o to provide data processing, printing, distribution and marketing campaign fulfilment services.
• Providers of data analytics services – to help us with compiling statistical or demographic data.
• IT service providers – for trouble shooting, system maintenance and IT issues.
• Professional advisers (e.g. auditors, tax advisers, lawyers) – as required to enable them to provide professional services to us to allow us to comply with our legal and regulatory requirements.
• Telephone tracking services to track telephone calls from specific ads across a variety of media channels.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in order to identify, confirm and/or reconcile lists of prospective residents, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

12. Data security

We have put in place appropriate 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.

13. Data retention

How long will you use my personal data for?

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to meet any legal, accounting or regulatory obligations.

To determine the appropriate retention period, we consider the nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the data, and whether those purposes can be achieved through other means. We also take into account applicable legal requirements.

In some cases, we may anonymise your personal data so that it can no longer be associated with you. We may use anonymised data for research or statistical purposes indefinitely without further notice to you.

For example:

We need your consent for some of the ways we use your personal information. You can remove that consent at any time.
The right to access the personal data we hold about you through a subject access request.
The right to be informed about our collection and use of your personal data.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete
The right to be forgotten, you can ask us to delete some of your information.
The right to restrict how we process your information.
The right to portability, you can ask us to help you move some of your information to other companies.
You have a right to ask that we provide your information in an easily readable format to another company.
The right to ask us to stop using your information, but only in certain cases.
We are required to retain basic information about our residents, including contact details and financial records, for six years after they cease to be residents for tax purposes.
We are also required to retain certain records for seven years to comply with the regulations of the Care Quality Commission.
Personal data submitted through contact forms will be retained for up to twelve months unless further correspondence or engagement occurs.
Data collected for marketing purposes will be retained until you withdraw your consent or unsubscribe.

14. What rights do I have about the use of my personal data?

You have certain rights regarding our use of your personal data under the UK GDPR.

We have listed below the rights you have over your personal data and how you can use them. (Please note that these are subject to restrictions, exemptions, and may only apply to certain types of information or processing):

You also have a right to object to us processing your information in certain circumstances. You can ask us to stop processing your information at any time. In certain circumstances we may not be able to do this or may not be required to do this. For example, if there are outstanding contracts between us, if we required by law to keep the information or if the information is relevant to a legal dispute then we may not stop processing your information.

15. Subject access requests

You have the right to request access to the personal data we hold about you. This is known as a subject access request. You may make a subject access request verbally, in writing or through other communication channels, including social media. We recommend written requests for clarity and record-keeping purposes.

We may need to request specific information from you to confirm your identity and ensure your right to access your personal data. This is a security measure to prevent unauthorised disclosure. We may also contact you to clarify your request, which may pause the response time until clarification is received.

We aim to respond to all legitimate requests within one calendar month. If your request is complex or if you have submitted multiple requests, we may extend the response time by up to two additional months. We will notify you if an extension is necessary and keep you informed of progress.

You will not be charged a fee unless your request is manifestly unfounded, excessive or repetitive. In such cases, we may charge a reasonable fee or refuse to comply. If we refuse your request, we will explain the reasons and inform you of your right to complain to the Information Commissioner’s Office.

16. Questions regarding this policy

Email address: [email protected]

Postal address: LifeCare Residences, 73 Albert Bridge Road, London, SW11 4DS

Telephone: 020 7935 0075

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).