This policy gives you information about how we collect and use your personal data through your use of this website and by accessing our services, including any data you may provide when you register with us or use our services.
This website is not intended for children and we do not knowingly collect data relating to children.
We are Healthspan Technologies Limited, trading as Kinly (referred to as Kinly, we, us or our in this privacy policy). We help older people to live independently by delivering on the services and financial support that are available to them, but that are largely not known about or difficult to understand.
Our company number is 15728029 and our registered office is located at Spaces West Kensington, Avonmore Road, London, United Kingdom, W14 8TS. As data controller, we look after and are responsible for your personal data. The information we process, and the reasons why, may vary across our products and services. We explain any differences in this privacy policy.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, or want to exercise any of your rights relating to your personal information, please contact us using the information set out in the contact details section below.
We may collect the following personal data about you:
Basic identity data such as your name, marital status, title, date of birth and gender.
Contact data: billing address, delivery address, email address and telephone numbers, including your marketing preferences and whether you wish to be contacted by third parties.
Residency data: the country you live in and national identifiers such as national insurance, national health or passport number.
Communications data: details of any contact we've had with you, including records and recordings of phone calls and written complaints.
Financial / Transaction data: bank account and payment card details, as well as details of payments you have made and products or services that you have purchased from us.
Special category data: information about your physical or mental health, including genetic or biometric information. We may get this information from application forms, notes and reports about your health and any treatment and care you've received or need, notes from calls and other communications we've had with you, referrals from insurance providers and records of medical services and treatment you've received. We receive this information from you, and not from any third parties.
Technical data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our website.
Usage data: information about how you interact with and use our website, products and services.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our services or use our eligibility tools;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you; or
give us feedback, provide a review of our services or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy on our website (www.kinly.org.uk/cookies) for further details.
Under data protection laws, we can only process your information if we have a legal reason (known as a 'lawful ground') for doing so. We rely on one or more of the following legal reasons:
Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure client experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to a newsletter from us. We also rely on consent when using your special category data to assist you to use our services.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Use | Type of data | Legal basis |
|---|---|---|
| To register you as a new client | (a) Identity (b) Contact (c) Residency (d) Communications |
Performance of a contract with you |
|
To provide you with our ongoing service including: (a) Submission of Attendance Allowance forms and other documentation to unlock services and financial support (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Communications (d) Financial / Transaction (e) Special category (f) Technical |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent (where we use your special category data to provide our services) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries |
(a) Identity (b) Contact (c) Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you. |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Communications (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, client relationships and experiences and to measure the effectiveness of our communications and marketing |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of client for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Special category data |
(a) Identity (b) Contact (c) Communications (d) Technical (e) Usage (f) Special category |
Consent, having obtained your prior consent to receiving direct marketing communications and receiving your special category data |
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Special category data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. We promise that we will never share your Special Category data with any third parties unless you have specifically authorised us to do so.
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or client service purposes.
For more information about the cookies we use and how to change your cookie preferences, please see our website or directly visit https://kinly.org.uk/cookies.
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Internal Third Parties who may employ staff to answer our telephone lines, process client information and respond to client queries.
External Third Parties who provide us with software applications, cloud storage and other technical support to manage our website.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, such as the International Data Transfer Agreement.
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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction data) for six years after they cease being clients for tax purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal
data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, you can contact us by email at info@kinly.org.uk, by post at Avon House, Avonmore Road, London, W14 8TS, or by telephone on 020 3957 9510.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our privacy policy under regular review. This version was last updated on 9th September 2024.
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, for example a new address or email address.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
