Privacy policy

Updated: 6.7.2022

What is Gubbe?

Gubbe is a home service for seniors. The content of the service is tailored to the needs of the client. The service includes outdoor activities, physical and mental activation, shopping assistance, company and help with household chores and technical equipment.

What is this Privacy Policy?

This Privacy Policy is a document that explains how Gubbe Ltd processes the personal data of subscribers, customers, contractor applicants and contractors. The aim of this Privacy Policy is to provide this information in a way that is as clear and as understandable as possible, but if there is anything unclear or you have any other questions about Gubbe's data processing, you can contact Gubbe's Data Protection Officer at privacy@gubbe.com.

Access to Gubbe's services requires your consent to the processing of personal data in accordance with this Privacy Policy, so we hope that you will read this Privacy Policy carefully. 

This Privacy Policy applies only to the processing of data by Gubbe directly. This Privacy Policy does not cover the processing of data by third parties and Gubbe is not responsible for the processing carried out by third parties.

The Data Controller

The Data Controller is the company (Gubbe Ltd), that is responsible for the controlling and processing of personal data.

Gubbe Ltd (Later ”Gubbe”, ”we”)
Registered No: 13878418
Email: info@gubbe.com
Postal address: 10 John Street, London, WC1N 2EB

Contact Details of the Data Protection Officer

Gubbe's Data Protection Officer

privacy@gubbe.com

Description of the Privacy Policy

This Privacy Policy describers how the Data Controller processes the personal data of

  • individual customers
  • contact persons of corporate customers
  • contact persons of public sector customers
  • end users of the service (typically a senior)
  • contractors that produce the service
  • contractor applicants

What Personal Data Do We Process?

We collect various types of personal data for the provision of Gubbe's services, sales and marketing purposes and for the development of the company's operations and services. In this section, we describe the types of personal data we process from different target groups. 

Target groups mean the following groups (short name used later in the document in parentheses).

  • potential subscribers and customers who are approached for sales and marketing purposes (sales and marketing audience)
  • individual customers who subscribe to the service, typically a relative of the senior (subscribers)
  • contact persons of corporate and public sector customers (company contact persons)
  • end-users of the service, typically a senior (end-user customers)
  • contracted contractors, so called "gubbes" (contractors)
  • contractor applicants (contractor applicants)

We will also briefly explain the purposes for which we collect and process that information. More information on the purposes and legal grounds for the use of this information is provided later.

Basic and contact details

For example

  • first and last names
  • email address
  • phone number
  • street address
  • language
  • year of birth
  • gender

From whom do we collect this information? Sales and marketing audience, subscribers, company contact persons, end-users, contractor applicants, contractors.
Principally for which purpose?
Sales and marketing purposes, maintaining customer and contractor relationships, delivering services as per our contractual obligation.

Specific identifying details

  • date of birth
  • social security number or equivalent national identifier

From whom do we collect this information? End-user customers, contractor applicants, applicants.
Principally for which purpose?
In some countries the social security number or equivalent is required per national regulation for the service contract made with the end-user customer. For contractors, such an identifier may be required for identification of the individual and security checks as providing the service involves independent work in the end-customer's home.

Other descriptive details related to individuals

In order to provide personalised services, we collect the necessary background information about the end-user customer. For example, we may collect and process descriptions to

  • housing
  • areas of interest
  • special requests
  • other details purposefully shared by the end-customer

From whom do we collect this information? End-user customers
Principally for which purpose?
For the provision of a personalised and tailored service and creation of a service plan.

Information related to the service and customer relationship

When providing the service and in customer service situations, we collect information related to the customer relationship. This information is not in principle personal data, but in some cases, especially when combined with other information, it may be classified as personal data. Examples of data collected in the course of providing the service: 

  • description of the events of the service visit
  • customer feedback received
  • details about subscriptions and billing
  • information about suitable contact hours

From whom do we collect this information? End-user customers, subscribers, company contact persons
Principally for which purpose?
To maintain the customer relationship as per our contractual obligations and for the development of our services.

Background information of contractors

Edellä mainittujen henkilötietojen lisäksi työnsuorittajahakijoilta (ja siten myös työnsuorittajilta) kysymme työkokemukseen ja koulutustaustaan liittyviä tietoja, esimerkiksi tiedot

In addition to the personal data mentioned above, we request information from contractor applicants (and therefore also contractors) related to their work experience and educational background, such as details about:

  • education
  • work experience
  • possbile healthcare qualifications
  • driving permit
  • other information relevant to the contractual tasks shared by the contractor applicant during the application process

From whom do we collect this information? Contractors, contractor applicants
Principally for which purpose?
In order to assess the suitability of the applicant for providing the Gubbe service and to be able to connect the contractor to a suitable customer.

Sensitive personal data related to health and well-being

In order to provide the Gubbe service, Gubbe needs to process some well-being and health data that are classified as sensitive personal data under the UK GDPR. The processing of these data by Gubbe is always based on the explicit consent of the data subject.

Data relating to well-being and health are collected from the data subject. We collect and process only the data necessary for the provision of the service, and such data as the data subject specifically wishes to be disclosed to the service provider or the subscriber's relative.

Examples of health and well-being information relevant to the provision of the service

  • description of state of memory
  • description of reduced mobility
  • description of reduced sensory capacity
  • superficial information about vital medications (such as medication for heart failure, epilepsy, diabetes and severe allergic reactions) 

Information may be disclosed to a relative and to the service provider providing the service visit with the explicit consent of the end-user customer.

Keneltä keräämme? Loppukäyttäjäasiakkaat
Pääsääntöisesti mitä tarkoitusta varten?
Sopimuksen mukaisten palvelujen tuottamiseksi. Esimerkiksi sopivan palvelukäyntejä toimittavan työnsuorittajan löytämiseksi, työnsuorittajan perehdyttämiseksi ja sovitun palvelun toteuttamiseksi, kuten avustaminen fysioterapiaohjelman suorittamisessa, toteuttamiseksi.

From whom do we collect this information? End-user customers
Principally for which purpose?
To provide services as per our contractual obligations. For example, to find a suitable contractor to provide the service visits, to train the contractor and to deliver the agreed services, such as assisting with a physical therapy programme.

Automatically collected data

To improve our digital services, we collect some information automatically from our websites and mobile applications, such as

  • Duration and time of a visit on our website
  • Actions taken on our website or our mobile applications
  • Information about the browser or model of the mobile device
  • Operating system
  • IP-address

From whom do we collect this information? From everyone who accesses our digital services (websites and mobile applications).
Principally for which purpose?
To monitor the performance of our digital services and improve our digital services.

Data collected from customer surveys

In order to develop Gubbe's services, various customer surveys are regularly carried out, which may include the collection of more detailed personal information than mentioned before. Participation in these surveys is entirely voluntary and the disclosure of data is subject to the customer's or subscriber's consent. In addition to service-related information, we may collect additional information in surveys, such as

  • Profession
  • Areas of interest
  • Family
  • Technology related preferences and habits

From whom do we collect this information? Voluntary survey-participants. Principally subscribers and sales and marketing audience.
Principally for which purpose?
For the development of our services and marketing.

Regular sources of personal data

In principal, personal data is collected form the data subject himself/herself through various channels. Personal data are not collected from external sources or services.

Where the data subject discloses the data himself/herself

Regular sources of information

Channels, through which data is principally disclosed through

  • online form
  • email
  • SMS
  • phone call
  • social media service messages
  • physical meetings
  • forms inside digital services and applications
  • chat messages with customer service

Regular situations where data subjects disclose information

End-user customers, subscribers, company contact persons

  • scheduling sales meetings
  • sales meetings
  • creating the service plan
  • ordering the service
  • creating the service contract
  • service visits
  • customer service situations
  • giving customer feedback
  • participating in raffles and other marketing campaigns

Contractors and contractor applicants

  • contractor application process
  • application
  • interview
  • creating the contract
  • support and guidance situations in relation to the contractual relationship

Automatically collected data

Cookies

Cookies are small text files that a website stores on your device. Cookies are used to improve the user experience of the website.

When navigating on the Gubbe website, the user is asked about the use of cookies. Cookies that are mandatory for the functionality of the website, such as logging in and remembering previous conversations, are set automatically, other cookies with separate consent. Other cookies include cookies to optimise the performance of the site's functions, as well as tracking and analytics cookies. Tracking and analytics cookies are used to monitor the use of the website and to improve services. Cookies that have already been enabled can be changed at any time on the Gubbe website.

Users can also block the use of cookies in their browser or set their browser to warn them when they try to install cookies. Please note that when doing so, some functionalities of the service may not work properly. For more information on cookies and how to delete them, please visit www.allaboutcookies.org.

Gubbe's websites use Google Analytics and other analytics tools to generate reports on website usage in order to improve the website and the service. More information about Google Analytics can be found at http://www.google.com/analytics. You can opt out of the collection of data by Google Analytics by downloading the browser add-on at https://tools.google.com/dlpage/gaoptout.

Information collected when using our other digital services

In the same way that we use cookies to collect information about our website users, we also collect information automatically when you use our other digital services, such as mobile applications.

As explained below, this information is mainly technical information about the use of the service. For example, in the case of mobile applications, this may include information on the device model and operating system used, the functionality used and pages visited within the application, the time of use, problems encountered during use.

The Purpose and Legal Grounds for Processing Personal Data

For what purpose do we process personal data?

Gubbe processes personal data for several purposes:

To provide you with services and to fulfil our contractual obligations.

Gubbe processes personal data primarily to provide services to its customers. Gubbe uses personal data to perform its obligations under the contractual relationship. Personal data is used for the provision of services and the management of the customer relationship. In the event that the user contacts customer service, the data provided will be used to find a response and to resolve any complaints.

Marketing and customer communications

Gubbe may process personal data to contact customers in connection with the service and to notify them of changes to services and products, and to market its services to customers. The data is also used for research and analysis to improve our digital services.

To improve quality and analyse trends

Gubbe may process information about the use of services in order to improve the quality of its services, for example by analysing various trends in the use of the services. For this purpose, we aim to use, when possible, anonymised and non-identifiable data.

To recruit contractors and manage assignments

Gubbe processes personal data of job providers and job seekers in order to establish and maintain an engagement relationship, for example to assess their suitability to provide service visits, to draw up an engagement contract, to find a suitable client.

Legal grounds for processing

Contractual obligation

Principally, Gubbe processes personal data in order to fulfil its obligations towards subscribers, customers and contractors arising from contracts with Gubbe and the aforementioned parties.

Consent of the data subject

Gubbe processes personal data that is not necessary for the purposes of fulfilling an existing contractual relationship or a legal obligation, but is necessary, for example, for the development of our activities, with the consent of the data subject. Consent is typically expressed by, for example, ticking a box on an online form.

Explicit consent of the data subject

Gubbe processes sensitive personal data, such as health-related data, with the explicit consent of the data subject. Explicit consent means that an expression of will is requested for strictly limited data for strictly limited purposes.

Consent can always be withdrawn as easily as it can be given. Depending on the case, consent can be withdrawn by changing the settings in the digital service or by contacting Gubbe's customer service at asiakaspalvelu@gubbe.com or the Data Protection Officer at privacy@gubbe.com.

Legitimate interest

Personal data may also be processed to maintain and develop services and business. In such situations, we will balance Gubbe's own legitimate interests against the privacy of the data subject, for example, by offering the opportunity to opt-out of our newsletters and direct marketing.

Legal obligation

In some cases Gubbe may have a legal obligation to process personal data.

Disclosing and transferring personal data

In what circumstances can we disclose personal data?

We share personal data within the Gubbe organisation and only to the extent necessary to provide and develop our services.

Personal data will be disclosed to contractors providing service visits (so-called "gubbet") to the extent necessary for the performance of the contracted service. Prior to disclosure, a written confidentiality agreement will be signed by the contractors.

In addition, information that is identified as personal data may be shared with a relative of the customer, or any other person expressly designated by the customer, with the customer's explicit consent.

Otherwise, personal data will not be disclosed to third parties outside the Gubbe organisation unless one of the following conditions applies:

It is necessary to achieve the purpose of this Privacy Policy

To the extent that third parties need access to personal data in order to perform services, Gubbe has taken appropriate contractual and organisational measures to ensure that personal data is processed only for the purposes set out in this Privacy Policy and in accordance with applicable law.

On legal grounds

Personal data may be shared with third parties outside the Gubbe organisation where there are reasonable grounds to believe that access to or use of the personal data is necessary:

(i) to comply with any applicable law, regulation or legal process 

(ii) to detect, prevent or address an abuse, security risk or technical problem

(iii) To protect the interests of Gubbe, users or the public, property or safety, as required by law. The parties concerned will be informed of the use of personal data in such cases where reasonably possible.

For other legitimate reasons

If Gubbe is involved in a merger, acquisition or other transaction, personal data may be transferred to a third party involved in the transaction. In such a situation, the confidentiality of personal data will be guaranteed and subscribers or customers will be informed prior to the transfer or change of privacy policy.

With explicit consent of the data subject

Personal data may be shared with third parties in situations other than those listed above where explicit consent has been obtained. Previously given consent may be withdrawn at any time.

Aggregate traffic data and other anonymous information related to the use of the website may be shared with advertisers, business partners and other third parties.

Data transfers outside Europe

Gubbe does not transfer personal data to countries outside the United Kingdom of Great Britain and Northern Ireland, the European Union or the European Economic Area. Exceptions to this are countries that have received a data protection equivalence decision from the European Commission.

Protection of Personal Data

Gubbe processes personal data with due care and in accordance with the requirements of applicable law.

Principles of data protection

Personal data are processed with due care and the data processed by the information systems are adequately protected. When personal data are stored on web servers, the physical and digital security of the hardware is adequately ensured. Gubbe will ensure that stored data, server access rights and other information critical to the security of personal data are handled confidentially and only by employees whose job description includes this.

How do we store Personal Data?

Personal data is stored on secure servers, which we manage together with service providers. The personal data stored is protected by security and access controls, including two-factor username and password authentication and appropriate data encryption.

Retention Period of Personal Data

Gubbe will not retain personal data for longer than is instructed by law and longer than is necessary to provide the services. The retention period depends on the nature of the data and the purpose of the processing. The retention period may therefore vary depending on the data and the purpose of the processing.

Once customers have indicated that their relationship with us is terminated, their personal data will be deleted or made anonymous within 90 days. The data will be kept after the end of the customer relationship in case of possible complaints. Similarly, the personal data of the contractors will be deleted or made anonymous within 90 days of the end of the contract.

The Data Subjects Data Protection Rights

In accordance with the Data Protection Law, data subjects have rights to their personal data processed by Gubbe. This section sets out these rights. For all matters relating to these rights or to the processing of personal data in general, please contact Gubbe's Data Protection Officer privacy@gubbe.com.

Right of access

Gubbe provides the data subject with access to his or her personal data that are processed. This means that the data subject may, upon his or her written request, be informed of the personal data collected and processed in relation to the register and the purposes for which such data are or have been used. Before access is granted, the applicant may be asked to prove his or her identity, if necessary.

Right of rectification

The data subject has the right to ask us to rectify personal information he or she thinks is inaccurate. He or she also has the right to ask us to complete information you think is incomplete.

Right to erasure

Data subjects may request Gubbe to delete their personal data from its systems. The measures in accordance with your request will be taken unless Gubbe has a legitimate reason not to delete the data. Data may not be immediately removed from all our backup or similar systems. Such backups will be deleted as soon as practicable.

Right to object processing

Data subjects may request restrictions on the processing of their personal data if the data are processed for purposes other than the provision of our services or the fulfilment of a legal obligation. Data subjects may also object to the further processing of their personal data if the processing is based on consent previously given. Objecting to the processing of personal data may result in a reduced ability to use Gubbe's services.

Data subjects always have the right to object to us using their personal data for direct marketing, market research or profiling by contacting privacy@gubbe.com

Right to restriction of processing

Data subjects may also ask Gubbe to restrict the processing of certain of their personal data. A request for restriction of data processing may result in a more limited access to Gubbe's website and services.

Right to data portability

Data subjects have the right to ask that we transfer the personal information he or she gave us to another organisation, or to himself or herself, in certain circumstances.

Exercising your rights

These rights can be exercised by sending a letter or email to the above addresses containing the following information: name, address, telephone number and a copy of a valid identity document. Gubbe may request additional information necessary to prove the identity of the data subject. Requests that are unreasonably repetitive, excessive or manifestly unfounded may be refused. If the data subject considers that the personal data processing measures are incompatible with the applicable legislation, the data subject may lodge a complaint with the local data protection authority.

Changing the Privacy Policy

Changes to this Privacy Policy may be necessary due to changes in legal requirements, changes to our privacy practices or changes to our business. Changes to this Privacy Policy will take effect as soon as they are posted on our website.

How to Complain?

If you have any concerns about our use of your personal information, you can make a complaint to us at privacy@gubbe.com.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

How to Contact Us?

If you have any further questions about our privacy practices, please contact us at privacy@gubbe.com.

A part of the family.
Gubbe is a preventive and rehabilitative elderly care service that supports the elderly to stay independent and active. We help with everything from household chores and guided exercising to caregiving tasks. The service is available to private homes and nursing homes - throughout Greater London.
Gubbe was founded in the Nordics in 2018, originally from Finland – the happiest country in the world.
Privacy policy

Contact us:
+44 20 3991 0033
info@gubbe.com

Gubbe Ltd
13878418