Privacy Policy

1. Who We Are

Everwarm Companions is a premium companionship and lifestyle support service based in Aylesbury, Buckinghamshire. We provide personalised companionship visits to older adults living independently at home and in care home settings across Aylesbury and Buckinghamshire.

For the purposes of data protection law, Everwarm Companions is the Data Controller responsible for your personal data. Our contact details are set out at the end of this policy.

We are committed to protecting your privacy and handling your personal data in a transparent, lawful, and secure manner, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. What Personal Data We Collect

We may collect and process the following categories of personal data:

2.1 Data You Provide to Us

• Name, phone number, and email address (from enquiry and consultation forms)
• Your relationship to the person requiring companionship
• Information about your loved one, including their name, age, location, interests, daily routine, health context relevant to matching a companion, and any particular preferences or sensitivities
• Correspondence you send us by email, phone, or contact form

2.2 Data We Collect Automatically

• Technical data such as your IP address, browser type, and operating system
• Usage data including pages visited, time spent on pages, and referring URLs
• Cookie data (see Section 9 below)

2.3 Special Category Data

In the course of providing our service, we may receive information relating to the health or wellbeing of the person receiving companionship. This is treated as special category data under UK GDPR and is handled with the highest level of care, processed only where strictly necessary and with appropriate safeguards in place.

3. How We Use Your Personal Data

We use your personal data for the following purposes and on the following lawful bases:

• To respond to your enquiry and provide a consultation, Lawful basis: Legitimate interests / Pre-contractual steps
• To deliver our companionship service, Lawful basis: Performance of a contract
• To match a companion appropriately to your loved one, Lawful basis: Performance of a contract / Legitimate interests
• To provide post-visit family updates, Lawful basis: Performance of a contract / Consent
• To manage our business relationship with you, Lawful basis: Legitimate interests
• To send service-related communications, Lawful basis: Legitimate interests (you may opt out at any time)
• To comply with legal obligations, Lawful basis: Legal obligation
• To improve our website and services, Lawful basis: Legitimate interests

We will never use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

4. Who We Share Your Data With

We do not sell, rent, or trade your personal data. We may share your data with:

• Our companion team members, on a need-to-know basis to deliver the service effectively and safely
• Technology service providers, including website hosting providers and email platforms, under strict data processing agreements
• Professional advisors, including legal, insurance, and accounting professionals, where necessary
• Regulatory or law enforcement authorities, where required by law or to protect the safety of any individual

All third parties who process data on our behalf are contractually required to handle it securely and only for the specified purpose.

5. How Long We Keep Your Data

We retain your personal data only for as long as necessary to fulfil the purposes set out in this policy, or as required by applicable law. Our standard retention periods are:

• Enquiry and consultation data (non-clients), 12 months from last contact
• Client records (active), Duration of the service relationship plus 6 years
• Client records (closed), 6 years from the end of the service
• Financial records, 7 years (statutory requirement)
• Website analytics data, Up to 26 months

Where data is no longer required, it is securely deleted or anonymised.

6. Your Rights Under UK GDPR

You have the following rights in relation to your personal data:

• Right of access, to request a copy of the personal data we hold about you
• Right to rectification, to request correction of inaccurate or incomplete data
• Right to erasure, to request deletion of your data in certain circumstances
• Right to restriction, to request that we restrict processing of your data in certain circumstances
• Right to data portability, to receive your data in a structured, machine-readable format
• Right to object, to object to processing based on legitimate interests or for direct marketing
• Rights related to automated decision-making. we do not carry out solely automated decision-making with legal effects

To exercise any of these rights, please contact us using the details in Section 10. We will respond within one calendar month. There is no charge for making a request.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

7. Data Security

We take the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Secure, encrypted transmission of data via HTTPS
• Access controls limiting who can view personal data
• Regular review of our data handling procedures
• Staff awareness of data protection responsibilities

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, notify you directly.

8. International Data Transfers

We do not routinely transfer your personal data outside of the United Kingdom. Where any transfer does occur, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements.

9. Cookies

Our website uses cookies to improve your browsing experience and to understand how visitors use the site. Cookies are small text files stored on your device. We use:

• Strictly necessary cookies, essential for the website to function correctly
• Analytics cookies, to understand how visitors use our site (with your consent)

You can control cookie settings through your browser. Disabling cookies may affect your experience of the website. By continuing to use this website, you consent to our use of strictly necessary cookies.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any material changes will be communicated via our website. The "Last Updated" date at the top of this page reflects the most recent revision. We encourage you to review this policy periodically.