Privacy Policy

Apcura Medical Ltd registered office is at Niddry Lodge, 51 Holland Street, London, W8 7JB. Apcura Medical Ltd is registered with the ICO under the Data Protection Register, our registration number is: ZA540748

For the purpose of Data Protection Legislation (as defined below) Apcura Medical Ltd is the data controller. References to “Care of a Kind”, “we”, “us” or “our” are references to Apcura Medical Ltd.

We take the privacy of your information seriously.

This privacy policy explains how we collect and use your personal information in connection with the provision of care services including:

  • through your use of our Website (as defined below) and any or any Care of a Kind application that we make available from time to time or by contacting us via any means including through our Website live chat, Facebook, by email or phone;
  • by being a service user (“Client”) or prospective Client of our care services including but not limited to: Home Care, Live-in Care, Respite Care, Palliative Care, Dementia Care, and Post Hospital Recovery Care (our “services”);
  • by being a person(s) arranging the care for and on behalf of a user (“Customer”);
  • by being next of kin to a Client or prospective Client of our Services; or
  • by interacting with our content and/or services including by applying to be one of our carers or employees.

This policy also applies to information held about suppliers and possible future suppliers, contacts and all other people we hold information about.

This policy does not apply to our employees or carers.

References to “you” are references to any natural person excluding any of our employees data but including any users, or prospective users of our care services, any user’ next of kin, any person accessing this Website.

Please read this privacy policy carefully.

  1. Definitions and interpretation
    1. In this privacy policy, the following definitions are used:

      “Data Protection Legislation”

      the EU General Data Protection Regulation 2016/679 and the UK Data Protection Act 2018 together with all other applicable legislation relating to privacy or data protection and including any statute or statutory provision which amends, extends, consolidates or replaces the same. The terms “personal data”, “data subject”, “controller”, “processor” ,”process” (and its derivatives) and “special categories of personal data” shall have the meanings given to them in the Data Protection Legislation;


      a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

      “UK and EU Cookie Law”

      the Privacy and Electronic Communications (EC Directive) Regulation 2003 as amended, extended, consolidated or replaced;

  2. What information we collect
    1. From our Website users / people who contact us via the Website:

      We may collect the following types of personal data about you, or a Client on behalf of whom you are accessing the Website, when you use the Website (either directly when you provide personal information to us via the Website, or indirectly through cookies used on our Website) or when you correspond with us (for example, by email) for any reason:

      (a) Your personal information collected when using our Website chat service including your name and chat history;

      (b) Name and contact information such as address, email addresses and telephone numbers;

      (c) Information about your device, including IP address, type of device, mobile device model, operating system, web browser type and version, city, timezone;

      (d) information about the website usage, including number of sessions, sessions’ duration, pages visited and buttons clicked;

      (e) information about referring websites: where the user clicked the link to get to the Care of a KindWebsite

    2. From our App users:

      We may collect the following types of personal data about you as the user of the App:

      (a) Name and contact information such as email addresses and telephone numbers;

      (b) Your personal information collected when using our App chat service including your chat history;

      (c) Username and log-in details including the SMS code assigned to you and sent to your mobile during the log in process;

      (d) Information about your device, including device model, operating system version, city, timezone;

      (e) Information about the app usage, including number and duration of sessions, when the app was accessed and which buttons the user clicked on the app during their sessions;

      (f) Information about which of our promotional content user interacted with before installing the app.

      When you use the App we may also collect the following information about the Client on behalf of whom you are accessing the App, or you if you are the Client:

      (a) First name;
      (b) Part of your post-code;
      (c) Details of any health conditions you choose to tell us about;
      (d) Care needs, including level of care support.

      For further information about the personal data that we collect about our Clients, not just through the App, please see section 2.3 below.

    3. From our Clients and prospective Clients:

      We may collect the following types of personal data about you as one of our Clients, or prospective Clients, in order to provide you with the Services:

      (a) Personal details of Client: name, address and telephone number along with photo ID;

      (b) A photograph of the Client;

      (c) Condition of a Client’s home;

      (d) Religious and cultural beliefs;

      (e) Next of kin, and their contact details;

      (f) Completed Herbert Protocol form, which will include health information (for Clients with dementia);

      (g) House entry instructions including: directions, access to a Client’s property and key codes for the same;

      (h) Personal medical information including past medical history, medication requirements, or whether the Customer has capacity to make decisions;

      (i) Care plans;

      (j) A Client’s care preferences, including whether carer’s are permitted to wear footwear in a Client’s home, details of a Client’s pets, favourite activities, dietary requirements;

      (k) Any other personal data provided to us during our continuous reviews and assessments.

      The personal data we collect will include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your health, ethnic origin or religious beliefs. Where required by Data Protection Legislation to seek separate permission from you in writing to process these special categories of personal data.

    4. From our Customers or next of kin of Clients:

      We may collect the following types of personal data about you, as our Customer:

      (a) Personal details of our Customer: name, address and telephone number along with photo ID;

      (b) Nature of their relationship with a Client;

    5. From applicants to Care of a Kind:

      We may collect the following types of personal data about you in connection with applying to be an employee or carer for Care of a Kind:

      (a) your name and date of birth;

      (b) your home address and contact details (including your mobile telephone number and email address);

      (c) your educational (including what training courses you have completed) and professional qualifications, your right to work, visa status, employment status;

      (d) your experience in providing care in a professional capacity;

      (e) what training courses you have completed;

      (f) the type of care you are interested in providing;

      (g) any other information about you that you disclose to us during the application process including your CV; and

      (h) details of how you heard about Care of a Kind.

  3. Purposes of processing and use of your personal information
    1. Any or all of the above types of personal data may be required by us from time to time in order to provide you with the best possible services and experience when using our Website, App or otherwise when providing our Services.

    2. Generally, personal data may be used by us for the following reasons:

      (a) internal record keeping;

      (b) consider your application where you have applied for a position with us;

      (c) improvement of our products/services;

      (d) data analytics;

      (e) carry out our obligations arising from any agreements entered into between you and us;

      (f) communicate with you;

      (g) administer the Website and App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and

      (h) transmission by email of promotional materials that may be of interest to you (where we have the right to do so),

      in each case, in accordance with this privacy policy and Data Protection Legislation.

      Specifically, Client and Customer personal data may be used for the following reasons:

      (a) to contact the Customer and/or Client and attend their address to give care;

      (b) to deliver quality care to the Client;

      (c) to take payment and grant refunds;

      (d) to carry out data analytics including but not limited to predictive health analytics;

      (e) to assist care workers, partner agencies and the police if the person it refers a Client goes missing;

      (f) to allow our carers access to a Client’s property;

      (g) to liaise with those designated to assist in care needs, or people who have power of attorney, to help with care delivery; and

      (h) to conduct periodic reviews, phone calls, spot checks, management visits, medication supervisions, and satisfaction surveys to ensure ongoing quality care delivery.

  4. Legal basis for processing
    1. Our processing of your personal data is necessary: (i) for the performance of contracts to which you will be a party and in order to take steps at your request prior to you entering into those contracts; (ii) where required by a legal or regulatory obligation; and (iii) for the purposes of legitimate interests pursued by us (and where this is not outweighed by your rights).

    2. We will only process special categories of personal information such as information about your health if such processing is necessary for the provision of health or social care or treatment or the management of health or social care systems and services or by obtaining specific consent from you (or on your behalf) at the time we collect it.

    3. If you completed the Data Protection Consent Form appended to the Care of a Kind Terms and Conditions you will have provided consent in accordance with Data Protection Legislation to the processing by Care of a Kind of your special categories of personal data.

    4. Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: (i) collecting personal information to provide you with a smooth and efficient customer experience; (ii) running our business; (iii) to provide the products and services you have requested; (iv) to prevent fraud; and (v) for the development of our own marketing (not for the purpose of sending unsolicited emails) , research and service.

  5. Disclosure of your personal information
    1. Except as expressly set out in this privacy policy we do not share, sell, or lease personal information about you to any third parties for their marketing use.

    2. However, we share your information with the following categories of companies as an essential part of being able to provide our products and services to you, as set out in this privacy policy:

      a) Professional service providers, such as marketing agencies, advertising partners and website and application hosts who help us run our business;

      b) Credit reference agencies, law enforcement and fraud prevention agencies, so that we can help tackle fraud and otherwise conduct background checks;

      c) Public bodies, regulators and law enforcement agencies such as the Care Quality Commission, as necessary to comply with our legal and regulatory obligations;

      d) Companies approved by you, such as social media sites (if you choose to link your accounts to us);

      e) Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

  6. Transferring data outside of the UK and EEA
    1. Your personal information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) due to us engaging a service provider which is located outside of the UK/EEA, for example IT hosting and maintenance, service providers whose servers are located outside of the UK/EEA.

    2. When we, or our permitted third parties, transfer your information outside the UK and European Economic Area, we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required by the Data Protection Legislation. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where: (i) the transfer is to a country deemed by the European Commission to provide adequate protection of your information; or (ii) where you have consented to the transfer.

  7. How long will we keep your information?
    1. We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us reviewing our files to check that information is accurate, up-to-date and still required.

    2. Where we are permitted to send you direct marketing communications, we may retain your contact information necessary for this purpose, (provided that you have consented to receiving them) until you unsubscribe from receiving the same from us (for more information about Marketing and Opting-Out, see below).

  8. Liquidation or Dissolution
    1. At Care of a Kind we are conscious that our primary aim is to deliver, to our Customers and Clients, outstanding, safe, effective, caring, responsive, well-led and person-centred care.

    2. If, for whatever reason, Care of a Kind was no longer operational either by dissolution or in liquidation, we will take steps to seek to place personal data in escrow or ring-fence the data, so as to seek to ensure it’s safe for the purpose of any administrative process.

  9. Your Rights
    1. You have a number of rights concerning the way that we use personal data. At any time, you have the right to:

      (a) be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third-party sources from whom it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);

      (b) request access to or a copy of any personal data we hold about you;

      (c) request the rectification of your personal data, if you consider that it is inaccurate;

      (d) request the erasure of your personal data, if you consider that we do not have the right to hold it;

      (e) object to your personal data being processed for a particular purpose or to request that we stop using your information;

      (f) request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data;

      (g) ask us to transfer a copy of your personal data to you or to another service provider or third party where technically feasible; and

      (h) ask us to stop or start sending you marketing messages at any time by using the below contact details.

    2. Requests to exercise these rights should be made in writing to We will respond within a reasonable period or in accordance with any statutory time limits contained in Data Protection Legislation. Some of these rights are not absolute and will be assessed when we receive a request.

  10. Marketing and Opting-Out
    1. We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone or text message (SMS).

    2. We will always treat your personal information with the utmost respect and never sell it to other organisations for marketing purposes.

    3. You always have the option of “unsubscribing” from our mailing list for email news alerts and updates at any time, thereby disabling any further such email communication from being sent to you, by clicking the link at the bottom of the email.

    4. Alternatively, you can send an email to with the word ‘remove’ in the subject line and the email address that you wish to be removed within the email. In addition, each electronic mailing we send you will contain details of how you can unsubscribe.

  11. Automated processing
    1. We do not carry out automated decision-making or profiling in relation to your personal data.

  12. Third party websites and services
    1. Care of a Kind may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website and App. The providers of such services have access to certain personal data provided by Users of this Website or App.

    2. Any personal data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any personal data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with Data Protection Legislation.

  13. Links to other websites
    1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

  14. Security
    1. Data security is of great importance to Care of a Kind and to protect your personal data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your personal data.

    2. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.

    3. We endeavour to do our best to protect your personal data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your personal data transmitted to the Website.

  15. Changes to this privacy policy
    1. We may change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and where necessary we will take action to bring any changes to your attention. Our registered users with known contact details will be notified via email.

  16. Contacting us and complaints
    1. If you have any questions about this privacy policy you may contact by email at

    2. If you have any concerns about our use of your information, you also have the right to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.

  17. Cookies
    1. The Care of a Kind Website may place and access certain Cookies on your computer either where you have consented to us doing so, or where it is essential for the website to function. We may use Cookies to improve your experience of using the Website and to improve our range of services. Care of a Kind has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

    2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

    3. More information about how we handle cookies can be found in our Cookie Policy.