Howz Apps Privacy Policy

We have carried out a data privacy impact assessment for this product in line with ICO recommendations. We are registered with ICO and have a strong commitment to data protection throughout our organisation. All staff complete annual refreshers on data privacy best practice, we consider data use at the beginning and throughout of any development work, and we welcome conversations with our users about their data and experience with our service.

You are the data owner. We (Howz - info@howz.com; Unit 45 Greenheys Business Centre, Pencroft Way, Manchester, M15 6JJ) are data controllers which means we decide how your information is processed, but we require your permission to collect and use your data.

The Data Protection Officer at Howz is Jonathan Burr. You can contact him via info@howz.com; Unit 45 Greenheys Business Centre, Pencroft Way, Manchester, M15 6JJ.

Personal information

Personal information means details that can identify you directly e.g. name, address, phone number or via a label that can identify you indirectly by linking items together. Indirect personal information is called pseudonymised data.

Anonymised data means that any personal identifying information is removed from the data entirely including any links so that it is not possible to identify you. Anonymised data is not personal information.

Our legal basis and purpose for collecting and processing personal information is:

BasisDefinitionProcesses
ContractProcessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contractCollecting data from sensors in the home, providing support services, contact regarding changes in the routine or system, enables the user to share their information with others as they wish
Legitimate InterestIt is in the legitimate interests we pursue as a business, except where such interests are overridden by your interests and fundamental rightsContinuously improve, develop and market our products such as new features, better performance and security

Failure to provide personal information may affect your experience and prevent provision of the service.

By downloading the app you are accepting the practices described in this Privacy Policy. We may change this Privacy Policy at any time. If we change the legal basis or the purpose of data collection we will request further consent.

Information we collect from you about you

You may be registered with Howz directly as the customer for monitoring in your house or as a family member ("VIP").

To register with the Howz system you are required to give us your email address as a user ID and a password, and the town nearest to the installed site. Howz has the right to email you directly with any service issues, changes to the system, changes detected in your data, and data summary reports in order to deliver your service.

To set up your Howz site you are required to enter your name, address, and postcode. In order to continue access beyond your free period you are required to enter your payment details.

Once your sensors are paired with your account we will process the information as part of service delivery. We use automated decision making to describe your daily routine and set alerts accordingly. This information is processed in a pseudonymised format. This information varies according your home set up as follows:

The information you collect is your responsibility and Howz has no responsibility for or control over the access to the content, information or data that you generate through use of Howz.

If you want to review or amend any data we store please contact us via info@howz.com and we can discuss your requirements. This may include providing you with a copy of the personal data stored about you, rectifying any details, restricting access to any specific details, or objecting to processing of personal data. If restricting processing of personal information we will discuss the impact of this on your service experience to enable you to make an informed decision about the processing we carry out. You can access your data at any time from a range of devices. You have the right to data portability. On request we can provide a copy of your personal data in a machine readable form.

If you contact us we may keep a record of that correspondence.

Information we collect about you and your device when you use the app

Every time you use Howz we may automatically collect information about:

We may collect this data using tools such as Segment, Adjust, Google Firebase, Google Analytics. We use this information to analyse app usage, improve performance and provide support to our users. The support function does require an identifier to be used for app usage.

The Howz service offers alerts as push notifications. In order to do this the app requests access to alerts and notifications within your phone settings. You can choose not to allow this at app set up. This will not affect your use of the app but will stop you receiving alerts from us via push notification, they will still appear within the app itself.

The Howz app when used for set up of a Howz Smart Home Kit will request use of the camera. This is to enable you to scan the barcode on the kit. You can decline permission and manually enter the code or you can set up your kit and then turn off the camera permissions in your phone settings.

We do not use any other trackers on your device and so no other permissions are required.

Who sees your information

The customer service team and clinical leads at Howz will see the information that identifies you to enable us to offer customer support. The Howz technical team will see the data from the sensors, but this does not enable them to see the personal information connected to the data and allows them to work on the system ensuring the data is managed effectively.

The customer service and accounts team will access your personal information to establish and maintain Direct Debits for ongoing Howz services.

Where trials are in place, data collected will be shared with the trial partner using anonymisation or pseudonymisation wherever possible. An additional fair processing notice and/or information sheet will be provided for each trial.

The addition of people to view your account is under your control. We call them VIPs as your information should only be shared with people you trust and who understand why you are sharing your information with them. You are responsible for correctly entering their email address and for checking this is correct before you share your data with them. You can withdraw permission for them to see your data at any time via the app.

How we store your data

All personal information you provide to us is stored on our secure servers. We only share your information through a secure transmission system within the internet. The data transmitted from the monitors in your home contains no personal identifiable information, is stored in the UK or EEA and is encrypted.

A pseudonym is created to enable us to identify your data within our analytics system. This method ensures your data is seen only by those you authorise and that you do not see other people’s information.

Your name, email address, contact phone number (and address if you supply this in communication via customer service) are stored within a system called Zendesk which is fully encrypted (stored in EEA or US under security shield) and only accessible to those who deal with customer service.

Your personal information from any hardware purchase you make (see howz.com for further details) is stored on an encrypted server provided by Shopify (stored in EEA or US under security shield) and this is only accessible by customer service staff within Howz. The link between your site and your personal information is stored on our secure server in a fully encrypted database.

Your name and address and payment details are stored within Chargebee (stored in EEA or US under security shield) and compliant with PCI DSS.

Your email address is stored within customer.io to enable the dispatch of emails regarding the service or changes within your site. The data is encrypted and stored in compliance with GDPR.

Any data that the Howz app stores on your mobile device is encrypted. If you backup your device to a service such as the Apple iCloud it is possible that your data might be stored in this service. It is not necessary to back up Howz in this way as all of the information is stored on our own secure servers.

How we use your information for our own purposes and service delivery

We use all information from attached sensors to provide a narrative of daily routine (list sensor activations) and to describe daily routine for a household. Automated decision making is used in the form of machine learning techniques to describe your daily routine from the data collected as part of our service to you.

We take activity from all sensors within the home and from this the system describes a typical 24 hour period of sensor activity at your site. Using analytic techniques the system will then estimate the timing of your daytime and nighttime, the time by which there is usually activity in the morning, and the longest average time with no movement. We call this your daily routine and this is shared with you after 7 complete days of site data. We use these estimates to create your alerts where there is a deviation from these timings to help you pick up when things are not as usual at your site. We also use these settings to look for changes over time which are shared with you via the app and email.

The outcomes of this analysis are displayed to you within the app under ‘Manage routine alerts’ and can be modified by you at any time. Your alerts can be switched off at any time within the app. If you would like to discuss your settings please contact us directly.

As we use machine learning techniques to estimate your settings it may be that things do not feel right to you, you can review your timeline within the app and see the information we have used in our calculations. It may be that the sensors are not picking up the activity you expected as they are not optimally placed - you can move the sensors at any time to address this. If the settings are not accurate, you may receive inappropriate alerts. If this happens, please edit your settings manually within the app, but we would also appreciate you contacting us as we can learn from these situations.

We may use the information you share in Howz to continuously improve and develop our products such as new features, better performance and security. We may also use the information to promote the service, evaluate the impact of the service, and share learning through publications. However, information used for these purposes will have all of your personal details removed, and no-one will be able to identify you from the information they see.

We will not sell or otherwise provide any information that identifies you personally to any third party without your permission or without giving you notice about it in this policy.

Usernames and email addresses

Email addresses are used to uniquely identify you in Howz.

We will use this email address as a way of contacting you or to help you reset your password if you have forgotten it. Please keep your password safe.

Your account can be linked to someone else’s email. This may be the case if you do not have or do not want to have an email address and another person is helping you so that you can use Howz. In this case you must be sure that you can trust that other person with your information.

You can choose to link your account to another email address at any time. Contact us if you wish to make a change.

Making changes and deactivating or deleting your account

You can remove a VIP at any time.

You may contact us at any time to make other changes to your account. You will need your registered site administration email address to confirm identity if you call us. We may ask for further details including the date of purchase if relevant or your site identifier before processing your request.

You may withdraw consent, deactivate or delete your account (your ‘right to be forgotten’) at any time via the app. You can also remove messages from your Timeline by contacting Howz customer service via the app or via telephone 0161 226 5353.

Whilst your account is deactivated you will not be able to record new entries into the app and you will not be able to open the app again. Your VIPs will not be able to see any new information or record new messages.

If you change your mind whilst your account is de-activated full use of the app can be restored to you by contacting Howz customer service as above.

If you request that your account is deleted your account will first be de-activated for 30 days. Once your account is deleted you will not be able to restore it. Account deletion means that all personal identifiable information will be deleted from our systems apart from financial records which are required by law to be retained for 10 years. The pseudonym will also be deleted meaning the data from your site can no longer be attributed to you and will become an anonymised dataset. This dataset will be preserved as it is used for machine learning purposes and will be incorporated into existing statistical calculations and system wide processes.

An archive of information stored within the app will be retained by us in accordance with our retention policy (10 years).

Cookies policy

What are cookies?

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this policy, we refer to all of these technologies as "cookies." Using Cookies helps Us to improve Our service to You.

Types of cookies We use

We may use:

How to control the use of cookies

If we use analytical cookies when you start using the app you will be given the option of agreeing to the use of analytical cookies. If you change your mind you can disable analytical cookies via the Settings page of the app at any time.

Further information

We have a full range of policies relating to data security, these documents can be shared on request. If you have questions or complaints regarding our use of your information and your privacy please contact us by email at info@howz.com or by phone 0161 226 5353 or by post:

Data Protection Officer

Unit 45 Greenheys Business Centre

Pencroft Way

Manchester

M15 6JJ

If you are not satisfied with our response you may contact the Information Commissioners Office with your concerns or a complaint. Please use this link https://ico.org.uk/make-a-complaint/ or contact them at:

ICO complaints

Wycliffe House

Water Lane

Wilmslow

CHESHIRE

SK9 5AF

 

2020/07/14-1