Version 1.1, Effective 7 January 2025
Previous version available here.
Thank you for using Lottie!
This policy sets out how Lottie processes personal data, please read this privacy policy carefully to understand our practices and your rights regarding your personal data. By visiting our website lottie.org (the “Platform”) or by otherwise providing us with your personal data, you acknowledge that your personal data will be processed as described in this policy and as required by the Data Protection Act 2018 and UK GDPR (the “Data Protection Legislation”).
DPO Contact Information: hello@lottie.org (please include in the subject line “FAO DPO”)
Data Controller: Lottie Organisation Limited, 52 Bermondsey Street, London, England, SE1 3UD (“Lottie”, “We”, or “us”)
ICO Registration: ZB201210
Through the use of our services Lottie may collect personal data concerning you (a “Care Seeker”) or concerning other individuals who may wish to receive care services (a “Care Recipient”). In some cases this will be the same individual.
In certain circumstances, Care Seekers may provide Lottie with personal data on behalf of a Care Recipient. Where this applies we require Care Seekers to confirm on behalf of the Care Recipient that they have consented to provide this personal data to us, or explicit consent in the case of special category personal data.
When we talk about “personal data” or “personal information”, we mean any information which we know relates to a living and identifiable person. We will always endeavour to treat personal information concerning Care Seekers and Care Recipients confidentially and respectfully, however please note that the GDPR and Data Protection Act 2018 only apply to living individuals and do not apply to deceased persons.
Where we refer to processing personal data as a Legitimate Interest, this means within our commercial remit as the provider of our Platform and other care software and systems, with consideration of the impact on the rights and freedoms of individuals.
We may collect and process the following personal data about You and may rely on one or more of the following lawful bases for processing:
| Personal Data | Purpose | Data Subjects | Lawful Basis |
|---|---|---|---|
| Contact and profile information (name, username, password, email, phone number, contact preferences) | To enable further contact regarding care options by Lottie and/or Care Providers | Care Seekers, Care Recipients | Consent, Legitimate Interests, Contract Performance |
| Address, preferred Care location | To enable Lottie to recommend suitable Care Services | Care Seekers, Care Recipients | Consent, Legitimate Interests, Contract Performance |
| Age, gender, relationship status | To enable Lottie to recommend suitable Care Services | Care Recipients | Consent, Legitimate Interests, Contract Performance |
| Call recordings | For training and monitoring purposes | Care Seekers, Care Recipients | Consent, Legitimate Interests |
| Data related to calls and transcripts | For training and monitoring purposes. To improve the services. | Care Seekers, Care Recipients | Legitimate Interests |
| User Analytics / Usage Data including IP address, browser type, device type, session data, how you use the website. | To improve the services | Care Seekers, Care Recipients | Consent, Legitimate Interests |
| Feedback, other user submissions (e.g. surveys) | To improve the services. To provide other initiatives such as rewards and prizes. | Care Seekers, Care Recipients, Partner users or other individuals | Consent, Legitimate Interests |
| Special Category Personal Data | |||
| Special care requirements (health data) | To recommend suitable care options | Care Recipients | Explicit Consent, Necessity for the provision of health and care services, Vital Interests of the Care Recipient (where consent is not possible) |
| Call Recordings, data related to calls, and transcripts (if incorporating health data) | To recommend suitable care options and ensuring proper functioning of the services. | Care Seekers, Care Recipients | Explicit Consent, Necessity for the provision of health and care services, Vital Interests of the Care Recipient (where consent is not possible) |
| Care Services Received from Care Providers (confirmation of receipt of services) | To confirm fulfilment of services and billing purposes | Care Recipients | Explicit Consent, Necessity for the provision of health and care services, To protect the vital interests of the Care Recipient (where consent is not possible) |
| Care Services Data (e.g. move-in date, move-out date) | To confirm fulfilment of services and billing purposes | Care Recipients | Explicit Consent, Necessity for the provision of health and care services, To protect the vital interests of the Care Recipient (where consent is not possible) |
The above personal data may be collected when You visit the Lottie website and provide the information through one of the forms such as a Shortlist, brochure request, other form request, or when You dial one of the telephone numbers displayed on our website.
Please note that telephone numbers provided for Community and Care Providers are managed and connected and recorded by Lottie for training and call monitoring purposes (see Calls and Call Recording below).
Lottie will ensure that there is a lawful basis for collecting and processing your personal data. Generally, your personal data will be collected in order to provide You with appropriate care services or information about a suitable community space. In these circumstances, Lottie processes your personal data in our legitimate interests as a care Platform provider and to fulfil our contractual obligations to you as a website user. Please refer to our website platform terms of use for more information.
On this basis, We will also process your personal data to:
We will carry out analytics to improve our products and services as set out above. You have the right to object to processing carried out, see the “What are your rights?” below for more information.
We may also process your personal data to comply with a legal obligation relating to:
In other cases Lottie will process your personal data on the basis of consent such as when determining your marketing preferences or providing you with the option to opt out of receiving further communications. Where possible, we will ask you for your consent prior to processing. You have the right to withdraw your consent or opt out from processing at any time.
Some personal data is considered particularly sensitive including but not limited to health, racial origin, political beliefs or sexual orientation. Lottie processes health data relating to special needs or conditions to provide you with the best care options. In providing the Platform, Lottie may process some health personal data in order to provide suitable choices of care or community spaces. We only do this where we consider it necessary for the purpose of providing care services, on the basis of explicit consent, or to protect the vital interests of the individual in urgent cases where consent may not be possible.
We only retain your personal data for as long as we need it or are required to keep it for legal reasons. If we no longer need your data, we will delete it. If you have an ongoing enquiry or account with us, we will keep personal data such as your email address, name and other details so you can log in and access our services for as long as you have an account.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes of processing the personal data and whether those purposes can be achieved through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In general this will be six (6) years following your last interaction with us. As outlined below, you can also ask us to delete your personal data and we will endeavour to complete this within one (1) month of your request. Call recording personal data is deleted after six (6) months.
Where personal data has been anonymised and aggregated such that it is no longer personal data, we may keep certain information indefinitely. This may include information such as usage data for analytical purposes, which we use to help us understand our customers, improve our products and provide services to our stakeholders, provided that individuals can no longer be identified.
We may need to share your personal data with third parties, some of whom we appoint to provide services, including:
These third parties are contractually required to only access personal data for the specific and limited purposes for which they are engaged and are subject to undertakings of confidentiality and compliance with privacy laws.
Additionally, we will disclose your personal information to the relevant third party:
As mentioned above, we anonymise and aggregate data to use for further analytics purposes, including providing analytical services to key sector stakeholders to support their business decision making. From time to time we may also post data insight trends and similar updates on our social media accounts, which are able to be accessed by the public in general. However, no third party stakeholder will be able to identify you from the information that we share in this way.
The telephone numbers provided by Lottie, including the contact details on each Listing, are connected by Lottie and are transcribed and recorded for training and monitoring purposes. By using the telephone numbers on our Platform, you acknowledge and agree that telephone conversations will be recorded and stored by Lottie within a secure server located in the UK and European Economic Area (EEA).
In certain contexts, in relation to Care Seekers, we may present an assigned number to Care Providers in place of personal numbers to ensure Care Seekers receive appropriate communications from Care Providers.
We take your safety and security very seriously and we are committed to protecting your personal data and health information. All information kept by us is encrypted and stored on our secure servers. We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We store your data on secure servers located in the UK and European Economic Area, where there are appropriate protection measures in place.
If there is no adequacy decision in place, we will protect your personal data by using the approved standard contractual clauses, UK addendum, or other lawful transfer mechanism with our providers processing personal data outside the United Kingdom.
You have certain rights under the Data Protection Legislation when we are acting as a data controller in respect of your personal data. You can exercise these rights at any time by contacting us at hello@lottie.org.
In some cases, such as where a rights request is received indirectly, we may request ID verification prior to proceeding with the request.
Should you have any issues, concerns or problems in relation to your personal data, or wish to notify us of personal data which is inaccurate, then please contact us at hello@lottie.org. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at any time. The ICO's contact details are available here: https://ico.org.uk/make-a-complaint/. We ask that you raise any concerns with us first so that we can seek to resolve any issues you may have.
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This policy may be updated from time to time. Please check back frequently to see any updates or changes to our privacy policy.
Questions, comments and requests regarding this privacy policy are welcomed and should be emailed to hello@lottie.org.