We are Sepuda Ltd, a company incorporated in England and Wales. Our company number is

12732659 and our registered address is 167-169 Great Portland Street, 5th Floor, London, W1W 5PF

Sepuda Ltd is committed to ensuring that your privacy is protected. We comply with the UK General Data Protection Regulation (“UK GDPR”) unless and until the UK GDPR is no longer directly applicable in the UK. We also follow all national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the UK GDPR and the DPA (together “Data Protection Legislation”). We are the data controller of data you pass to us pursuant to this policy. Our Data Protection Officer can be contacted at dpo@sepuda.com.

This Privacy Policy [together with our website terms and conditions and cookie policy] sets out how we collect personal information from you and how the personal information you provide will be processed by us. By visiting the website at www.sepuda.com (the “Website”) you are accepting and consenting to the practices described in this Privacy Policy. If you do not consent, please do not submit any personal data to us.

What information does Sepuda Ltd hold and how will we use it?

Information collected by us

When you enquire about our care and support services and during the course of providing care and support services to you, we collect the following personal information when you provide it to us:

• Your name, home address, date of birth and contact details (including your telephone number, email address) and emergency contacts (i.e. name, relationship, email address and home and mobile numbers)
• Your allergies and any medical, physical or mental conditions and in particular your care needs
• Your likes, dislikes and lifestyle preferences (including your religious beliefs or other beliefs of a similar nature, racial or ethnic origin, politics, genetics, health, sex life, and sexuality (so far as they relate to providing you with suitable care)
• credit or direct debit details (if you pay for some or all of our services using one of these methods)
• Your feedback and contributions to questionnaires and surveys about the service we offer
• Your complaints, compliments or concerns about the service we provide
• Any accidents and incidents or near misses you may have been involved in whist on our premises or whilst our employees are delivering a regulated service to you – this may include details of injuries and treatment you may have received

When using our website, we collect standard internet log information including:

• IP address
• Details of the pages you visit
• General details about the type of computer or device that you are using

This is statistical information only which we collect in order to find out the numbers of visitors to our site and the pages they have visited. This information collected in such a way that it is not used to identify individuals. Where we do collect personal information on the website, this will be made obvious to you through the relevant pages. Further details can be found in our cookie policy.

Please be aware that our website may provide you with links to other websites. If you follow a link to any other website, please note they have their own privacy promises. We do not accept any responsibility or liability for the privacy and security practices of such third-party websites and your use as such is at your own risk.

Information collected from other sources

We also obtain personal information from other sources such as:

• Your allergies and any medical, physical or mental conditions and in particular your care and support needs, from any appropriate external social or health care professionals (including your GP)
• Your name, home address, date of birth, contact details, NHS number, needs assessments and financial assessments from any appropriate external social or health care professionals (including any relevant public body regardless of whether you are publicly funded)
• Your likes, dislikes and lifestyle preferences (including your religious beliefs or other beliefs of a similar nature, racial or ethnic origin, politics, genetics, health, sex life and sexuality so far as they relate to providing you with suitable care) from your family, friends and any other person you have nominated as your representative
• Your Attorney or Deputy (if applicable)

How we use your personal information

We use your personal information to:

• Prepare, review and update a suitable care plan, describing the nature and level of care and support services which you have requested we supply to you
• To communicate with you, your representatives and any appropriate external social or health care professionals about your individual needs and personalise the service delivered to you
• Make reasonable adjustments, when required, to meet your individual needs and to ensure we have suitable facilities to ensure your safety
• Invoice you for the care and support services in accordance with our terms and conditions
• Carry out quality assurance procedures, review our service and improve our customer experience (please note that feedback can also be provided anonymously)
• Send information about our services which we believe you may be interested in. You may unsubscribe from this at any time
• Notify you about changes to our services which are relevant to you
• Monitor how effective our services are and to make sure that the services we provide meet your needs
• Improve your experience of our website and to ensure that the content is presented in the most effective way

Who we share your personal information with

• We regularly share your medical information with appropriate external social or health care professionals (including your GP and pharmacist) and any individuals you have nominated as your representative. This data sharing enables us to establish the type of care and support you need. It also allows us to design the right care package to suit your individual circumstances, including if (in future) you decide to receive care from an alternative provider.
• We will share personal information with law enforcement or other authorities if required by law. This includes information required by public bodies to evidence our compliance with the applicable regulatory framework. We are also required to share personal information with external social or health care professionals, including public bodies and local safeguarding groups (in some circumstances) to ensure your safety.

We will not share, sell or trade your personal information with any other third party.

At this time, we do not share any data for planning or research purposes for which the national data opt-out would apply. We review all of the confidential client information we process on an annual basis to see if this is used for research and planning purposes. If it is, then individuals can decide to stop their information being shared for this purpose. You can find out more information on the NHS website and Digital Social Care.

In order to deliver our service to you we rely on third parties to provide specialist support to us. To provide this support they will have access to, or a duty of care over your personal information. These providers are:

• IT and Telecoms Support companies – to ensure the safe, secure and resilient operation of our IT infrastructure including computers, servers, phones and mobile devices
• Software support companies – to provide specialist support and resolve issues with the software that we run, for example the systems we use to store and manage your customer records
• Marketing systems providers – to organise marketing communications and for the delivery and analysis of email communications
• Data archiving companies – responsible for the secure storage and destruction of records. These providers are under a written contract to ensure the same level of privacy and security that we promise to you.

Whether information has to be provided by you, and if so why

The provision of your medical, physical or mental condition is necessary to enable us to create a care plan and to provide you with suitable care and support services. Without this information, we will not be able to assess your care needs or provide any care services to you.

The provision of your name, home address is required so that we can arrange a care worker to attend your home to deliver the services and so that we can invoice you for the fees.

How long your personal information will be kept

We will hold the personal information kept within your electronic customer file for the length of your contract plus 7 years

We will hold financial records and transactions for 7 years in line with our legal requirements

Cookies

The Website uses cookies to distinguish you from other users of the website. For detailed information on the

cookies we use and the purposes for which we use them, please see our Cookie Policy on our website.

Use Made of the Information

We may use the information we receive and/or collect about you to:

• Fulfil our obligations under any contract that we have entered into with you or with a Service User that you represent, and to provide you or the relevant Service User with information or services that you or the Service User has requested
• Send you newsletters and marketing information if you have consented to us doing so
• Notify you of products and services that we feel may interest you, or permit third parties to do so if you have provided the appropriate consent
• Monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website

Sepuda Ltd processes personal information for certain legitimate business purposes, which include some or all the following:

• Where the processing enables Sepuda Ltd to enhance, modify, personalise or otherwise improve the website, its services or communications
• To identify and prevent fraud
• To enhance the security of the network and information systems of Sepuda Ltd
• To better understand how people interact with the websites of Sepuda Ltd
• To administer the website and carry out data analysis, troubleshooting and testing; and
• To determine the effectiveness of promotional campaigns and advertising

If we obtain consent from you to do so, we may provide your personal details to third parties so that they can contact you directly in respect of services in which you may be interested.

Where we are processing personal data that we have obtained via the website on the basis of having obtained consent from you, you have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information from us) please let us know by contacting us via the contact us page on our website. Please bear in mind that if you object, this may affect our ability to carry out the tasks above for your benefit.

If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by clicking the “Unsubscribe” option in any email we send to you and providing the details requested or by contacting us via the ‘’contact us’’ webpage and we will take steps to ensure that this information is deleted as soon as reasonably practicable.

We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent, unless required to do so by law.

Third Party Sites

Our website may contain links to third party websites, including websites via which you are able to purchase products and services. They are provided for your convenience only and we do not check, endorse, approve or agree with such third-party websites nor the products and/or services offered and sold on them. We have no

responsibility for the content, product and/or services of the linked websites. Please ensure that you review all terms and conditions of website use and the Privacy Policy of any such third-party websites before use and before you submit any personal data to those websites.

How Safe is your Information?

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Protecting your security and privacy is important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Legislation. The website is protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.

We will do our best to protect your personal data but the transmission of information via the Internet is not completely secure. Any such transmission is therefore at your own risk.

Disclosure of your Information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you
• Third parties who may wish to contact you in respect of services or products they offer or sell which may be of interest to you, provided we receive your consent to such disclosure; and/or advertisers and advertising networks that require the data to select and serve relevant adverts to you and analytics and search engine providers that assist us in the improvement and optimisation of the website

Please note, we may need to disclose your personal information where we:

• Sell any or all of our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller
• Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or
• Need to disclose it to protect our rights, property or the safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction

Your Rights in Respect of your Data

If any of the information you provide to us via the website changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us via the ‘’Contact Us’’ webpage on our website.

If you wish to access or rectify the information we hold about you, or request that such information be transmitted directly to another data controller, please contact us via the ‘’Contact Us’’ webpage on our website. We shall process your request to access your information within one month of receipt, or we will let you know within that timeframe if we need more information from you. We will process your request free of charge.

To request that your information is deleted or if you wish to restrict or object to the processing of your information, please contact us via the following ‘’Contact Us’’ webpage on our website.

If you have any complaints about our use of your personal data, please contact us. You also have the right to complain to the relevant supervisory authority in your jurisdiction. In the UK, the supervisory authority is the Information Commissioner’s Office. Contact details for the ICO can be found at https://ico.org.uk/.

If you have any further queries or comments on our Privacy Policy, please contact us via ‘’Contact Us’’ webpage on our website or you can contact us by emailing dpo@sepuda.com. We also welcome your views about our website and our Privacy Policy.

Note: This policy was last reviewed in August 2023