Privacy Policy

This Privacy Policy describes how personal data of Users of LifeLibrary and the residents of the care homes is processed.

1.What is Personal Data and Other Related Terms Used in This Privacy Policy?

In this Privacy Policy we use the following terms:

Personal data - means any information relating to an identified or identifiable natural person (‘data subject’);
Data subject - is an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Controller - means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law;
Processor - means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
Consent - of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
GDPR - means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

In case you see any other capitalized terms, please refer to our T&C to check their meaning.

2.Who is Who, What Kind of Personal Data is Processed and on Which Basis?

At different stages of using the LifeLibrary different types of data are collected and processed. In the table below you may find the exhaustive list of data, the controller and processor of such data and a legal basis for processing.

For your convenience, we duplicate the T&C’s definitions of the main roles used within LifeLibrary:

User - a care home purchasing the access to the LifeLibrary;
Permitted User - a person added to the LifeLibrary’s Account by User or on its behalf according to the terms of T&C and Appendix to the T&C;
Manager - a person acting on behalf of the User who is responsible for adding Permitted Users to the Account;
Supporter - a person acting on behalf of a Resident, may be the custodian of the Resident;
Resident - a person receiving caring services by the care home.

Data	Data subject	Controller	Processor	Sub-processor	Legal basis
Name, email, password	Manager	TheGrey MatterzLTD	TheGrey MatterzLTD	-	Article 6 I lit. b GDPR - processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services.
Phone number* * provision of phone number is optional	Employees (Manages, Life workers and carers), Supporter	TheGrey MatterzLTD	TheGrey MatterzLTD	-	Article 6 I lit. a GDPR - the data subject has given consent to the processing of his or her personal data for one or more specific purposes (receiving a temporary password in WhatsApp; receiving other informational messages concerning LifeLibrary)
Name of the Resident, their photo and date of birth	Resident	Supporter	User/Manager on behalf of User	Permitted Users on behalf of User	Article 6 I lit. a GDPR - the data subject has given consent to the processing of his or her personal data for one or more specific purposes On certain occasions Article 6 I lit. b GDPR may serve as a legal basis for processing in case the User enters into direct contract with Supporter acting on behalf of the Resident.
Name of the Resident, their photos, email, answers to questions concerning interests/life of Resident containing personal data of such Resident, including special categories of personal data	Resident	Supporter	User	Permitted Users on behalf of User	Article 6 I lit. a GDPR - the data subject has given consent to the processing of his or her personal data for one or more specific purposes, AND Article 9(2) lit. a GDPR – the data subject has given explicit consent to the processing of those personal data

Additionally, we are excited to keep you in the loop with a variety of exclusive new offers and other informational campaigns. By sharing your email with us, you're giving your consent to receive these updates, ensuring you're always informed about the latest opportunities and benefits. In such a case your consent will serve as a legal basis for such mailings.

In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured in User’s premises and as a result his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d GDPR - processing is necessary in order to protect the vital interests of the data subject or of another natural person.

Please note that our application is not intended to offer any services directly to children. We do not knowingly collect information from children.

TheGreyMatterz will use the anonymous information, namely information which does not relate to data subject or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable for statistical and research purposes.

Each Party shall ensure that it has in place appropriate technical and organisational measures, to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting personal data, ensuring confidentiality, integrity, availability and resilience of its systems and services, ensuring that availability of and access to personal data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of the technical and organisational measures adopted by it).

3.How Long Do We Store Your Personal Data?

The data collected by Google Analytics in the form of pseudonymous user profiles will be deleted no later than 14 months after the last new entry in the respective user profile.

In all other respects we delete your personal data as soon as they are no longer needed for the purposes pursued with the collection and processing and as far as no legal storage obligations stand in the way.

4.Do We Use Cookies in Lifelibrary?

Yes.

Cookies are small text files that are sent from a web server to your browser and stored on your computer's hard drive. This makes it possible to recognize you when you visit the application again. In this way we can guarantee a better functionality of the site and carry out e.g. web analyses. Most browsers are set to automatically accept cookies. You can deactivate the storage of cookies in your browser and have the possibility to delete them from your hard disk at any time. We would like to point out to you that a use of our offers in the application without cookies may only be possible to a limited extent. However, you can also use your browser only to prevent certain cookies from being set (e.g. cookies from third parties), for example if you want to prevent web tracking. Please refer to your browser's help function for more information.

If you visit our application and consent, we use Google Analytics, a web analysis service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google). Google Analytics uses cookies to enable an analysis of your use of the application. The information about your use of the application is usually transferred to a Google server in the USA and stored there. However, Google will reduce your IP address within member states of the European Union or in other signatory states to the Agreement on the European Economic Area beforehand and thus make it anonymous. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of the application, Google will use this information to evaluate your use of the application in order to compile reports on activity.

You can revoke your consent to web analysis and the related use of cookies as follows: On the one hand, the storage of cookies can be prevented by a corresponding setting of your browser software. Secondly, you can prevent the collection and transmission of data relating to your use of the application (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link. Alternatively, you can prevent Google Analytics from collecting data by setting an "Opt-Out-Cookie" on your computer.

Opt-Out-Cookie
Further information on data protection at Google Analytics can be found at: https://www.google.de/intl/de/policies/.

5.What Are Your Rights With Respect to Protection of Your Personal Data?

The right to be informed - that’s an obligation to inform you how your personal data is used (and that’s what we’re doing in this Privacy Policy).
Right of access - The Controller offers you access to your personal data which is being processed. This means you can contact processor and request from us a confirmation whether or not your personal data are being processed and if so, you have the right to request access to your data, which will be provided to you in the form of a so-called "registry" (stating, in particular, purposes, categories of personal data, categories of recipients of personal data, storage periods or criteria for determining storage periods).
Right to rectification - You have the right to have inaccurate personal data stored about you rectified.
Right to erasure - You may also ask to erase your personal data from the systems. We will comply with such requests unless we have a legitimate ground to not delete your personal data.
Right to restriction of processing - You may request to restrict certain processing of your personal data. If you restrict certain processing of your personal data, this may lead to fewer possibilities to use our application.
Right to data portability - You have the right to receive your personal data in a structured, commonly used and machine-readable format in order to transmit the personal data to another controller.
Right to object - that’s a right for you to object to processing your personal data (for example, if you object to processing your data for direct marketing). Please note that this right cannot be exerciable with regards to anonymized data.
Rights in relation to automated decision-making and profiling - that’s a right you have for us to be transparent about any profiling we do, or any automated decision-making.
Right to withdraw Consent - that’s the right to revoke any consent you may have previously given the controller or processor at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted with your consent prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
How to use your rights - You may exercise your rights above in writing by sending an email to the contact details in Contact Us. In case your request concerns the data processed or controlled by either User or Supporter, please contact them. You will not have to pay a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may require confirmation of your identity depending on your request. We respond to all requests we receive from individuals wishing to exercise their data rights in accordance with applicable data protection laws.

6. Can This Privacy Policy Be Amended?

Yes.

We may amend this Privacy Policy from time to time. The new version will come into force upon its publishing in our application. You may always find out whether our privacy policy was amended by checking the “last modified” legend on the top of the page.

7. How to Contact Us?

You may send your inquiries or requests to the following email: support@lifelibrary.io

Our legal details:

Name: TheGreyMatterz LTD

Registered address: 25 Airedale Road, London, England, SW12 8SQ

Company registration number: 12994452