Updated: July 2020

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users. This policy is designed to ensure that we safely handle your personal data in accordance with relevant regulations and legislation such as Data Protection Act 1998 and EU General Data Protection Regulations 2018 (the “Data Protection Regulations”).

1.2 This policy applies in those cases where we act as a data controller for the personal data of our website visitors and service users. This means those cases where we can decide the purposes and method of processing your personal data.

1.3 By using our website and agreeing to this policy, you also consent to our use of cookies in accordance with the terms of this policy.

1.4 These privacy rules explain what data we may collect from you, what we will do with that data and explains how you can you limit the publication of your information and how you can choose whether or not you would like to receive direct marketing communications.

1.5 In this policy, "we", "us" and "our" refer to BePeers LTD. Further details about us can be found below, in section 10 of this Privacy Policy.

1.6 In this policy, you ('caregiver') and/or your dependent will be referred to as “you” or as a “user” or as "users" or as "yours".

2. How we use your personal data

2.1 In this Section 2 we set out: the general categories of personal data that we may process; the purposes for which we may process personal data; and the legal basis of the processing in each case.

2.2 We may process data about your use of our website and services ("​usage data​"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website or service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account data ("​account data​"). The account data may include your name, email address, contact phone number, postal address and employer details. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.

2.4 We may process personal data that is provided in the course of the use of our services ("service data​"). The service data may include your name, email address, home address, contact telephone number and credit card details. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.

2.5 We may process information contained in any enquiry you submit to us regarding our services ("​enquiry data​"). The enquiry data may be processed for the purposes of offering you relevant services provided by us. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.

2.6 We may process information you provide to us during your use of our services (such as through our chat system) (“Personal Information”). Personal Information may include personal details, details of your employment, relationships, health or personal matters of your and/or your dependent. We do not store any of your Private Information and it is deleted from our servers immediately following the ending of your session. Our Coaches have been told not to record or take notes of your Personal Information, except with your express permission (which you do not have to give). Even if you choose to give permission to record Personal Information you have a right to ask for it to be erased at any time (except where such information must be retained for legal reasons).

2.7 We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website ("​transaction data​"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying goods or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.8 We may process any of your personal data identified in this policy where necessary for administrative purposes including in the exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely for administrative record keeping, processing transactions and maintaining business records or for the protection and assertion of our legal rights.