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.
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
Postal address: 10 John Street, London, WC1N 2EB
Gubbe's Data Protection Officer
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).
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.
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.
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.
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
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.
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:
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.
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:
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.
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
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.
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.
To improve our digital services, we collect some information automatically from our websites and mobile applications, such as
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.
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
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.
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.
Channels, through which data is principally disclosed through
End-user customers, subscribers, company contact persons
Contractors and contractor applicants
Cookies are small text files that a website stores on your device. Cookies are used to improve the user experience of the website.
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.
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.
Gubbe processes personal data for several purposes:
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.
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.
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.
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.
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.
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.
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 email@example.com or the Data Protection Officer at firstname.lastname@example.org.
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.
In some cases Gubbe may have a legal obligation to process 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:
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.
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.
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.
Gubbe processes personal data with due care and in accordance with the requirements of applicable law.
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.
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.
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.
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 email@example.com.
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.
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.
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.
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 firstname.lastname@example.org
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.
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.
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.
If you have any concerns about our use of your personal information, you can make a complaint to us at email@example.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
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
If you have any further questions about our privacy practices, please contact us at firstname.lastname@example.org.