Inloco Privacy Policy

Effective date: 1 June 2020

Our commitment to you

At Inloco, your privacy is a top priority. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly. We do not compromise your privacy and we have designed and built Inloco with your privacy in mind. We strive to be transparent in the way we process your data and to communicate with you clearly, so you can easily understand the data we collect, why we collect it and what we do with it. 

Introduction

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Site” means the webapp and the website www.myinloco.com, including all Services made available via the webapp and the website.

1. Important Information and who we are

Purpose of this Privacy Policy

This privacy policy aims to give you information on how we collect, use, process and disclose your personal information, in conjunction with your use of Inloco. By using and interacting with the Site, you consent to us processing your personal data in accordance with this privacy policy. If you see an undefined term in this privacy policy, it has the same definition as in the Terms of Use.

Inloco is not directed to children under 15 years, our minimum childcarer age is 15 and we do not knowingly collect data relating to children under 15 years. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

You are responsible for the type, detail and nature of the information that you choose to put on your profile and/or other information that you share with other users. Please consider carefully the information that you choose to share with others.  As stated in the Terms of Use, you are also responsible for the security of your profile by ensuring that you have a robust and unique password, that you do not share it with anyone and that you notify Inloco promptly with any security concern. We will not be liable for any unauthorised transactions or activity entered into using your name and password.

Controller

My Inloco Limited is the data controller and responsible for your personal data (collectively referred to as ”Inloco”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO  in the following ways:

Mail: My Inloco Ltd, Needlemakers, Watts Green, Chearsley, Bucks, HP18 0DD

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Information that is necessary for the use of the Inloco platform

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about others that you provide to us with, including (but not limited to) information that you provide by completing your profile or by creating a booking on the Site.  You represent and warrant to us that you have obtained the express consent from the individuals whose data you provide us with.  For the avoidance of doubt, any reference in this privacy policy to your data shall include data about other individuals that you have provided us with.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, nationality, identity documentation,  profile picture, date of birth and gender.
  • Contact Data includes billing address, home address, email address, telephone number and parent email address if a childcarer is under 18 years old.
  • Financial Data includes bank account and/or payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, services or bookings made or provided by you, membership details, the information you add about yourself to your public profile , schools (if added), your connections and favourites, your preferences, reviews, recommendations, referrals, in app messages, feedback and survey responses.
  • Usage Data includes information about how you use our web app, site and services and details relating to your bookings / booking requests such as, the age, and gender of the children and the booking location.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. This information is used for the operation of the Site and the services provided by Inloco, and to provide general statistics regarding the use of the Site and services.

In the course of providing services to you, we do not collect information that could reveal your (or your childrens) racial or ethnic origins, sexual orientation, political opinions, physical or mental health, religious or philosophical beliefs or trade union membership. Such information is considered Special Categories of Personal Data under GDPR. We would only collect this information where you have given your explicit consent or one of the other exemptions apply (i.e. it is necessary to comply with our legal obligations).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with childcare services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, social media, on our Site or otherwise. This includes personal data you provide when you:

  • sign up and create an account and public profile on our Site;
  • become a member;
  • use the Site and services provided;
  • meet with one of our employees, ambassadors or consultants;
  • request marketing to be sent to you;
  • complete a form on the Site, or in person, requesting us to contact you;
  • enter a competition, promotion or survey;
  • submit an application for a role within Inloco; or
  • make a complaint or give us feedback or contact us.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie policy for further details.

Third parties or publicly available sources

We will receive personal data about you from various third parties and public source as set out below:

  • Technical Data or Usage Data from analytics providers or search information providers; and
  • Employment, Identity and Contact Data from third party recruitment agencies, where relevant.

4. How we use your personal data

We will only use your personal data to operate the Site, the web app and the services you provide or have requested including enabling payment by Childcarers and Families.  Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by updating your preferences in your account settings.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Basis for processing
To register you as a User, create your profile and complete ID verification
  • Identity
  • Contact
  • Profile
  • Performance of a contract with you
To process your booking and services, such as:
  • (a) Manage your payments, membership, in app messaging, reviews and building your network
  • (b) Collect and recover money owed to us
  • Identity
  • Contact
  • Profile
  • Financial
  • Transaction
  • Profile
  • Usage
  • Performance of a contract with you
  • Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, such as:
  • (a) Notifying you about changes to our service, terms or privacy policy
  • (b) Asking you to leave a review
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, fundraising initiative, promotion, competition or complete a survey
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (to study how users use our services, to develop them and grow our business)
To administer and protect our business and Site including:
  • troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
  • Identity
  • Contact
  • Technical
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you:
  • measure or understand the effectiveness of advertising and Site design and services
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Technical
  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Technical
  • Usage
  • Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  • Identity
  • Contact
  • Technical
  • Usage
  • Profile
  • Marketing and Communications
  • Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We may use your personally identifiable information to inform you of other products or services available from Inloco and our partners.

You will only receive marketing communications from us if you have opted in to receive the requested information from us. We do not sell, rent or lease or provide in any other way our users lists to third parties.

We may also contact you via surveys to conduct research about your opinion of our website and services.  

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging in the “communication setting” page of the Site and checking or unchecking relevant boxes to adjust your communication preferences.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and applicable law.

You agree that Inloco may share data with third parties providers. The types of third party service providers whom we share your information with includes:

  • Affiliates of Inloco;
  • Payment providers (including online payment providers and fraud detection providers) for the purposes of providing services to us, for example when they process information such as credit card payments;
  • Childcarers and Families for the purposes of fulfilling the childcare services;
  • Third party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers (including cloud providers) and system administrators, third parties who host and manage data or provide programming or technical support, conduct reference checks on candidates on our behalf;
  • Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services;
  • Third party analytics partners to analyse website traffic and understand user needs and trends or third party marketing service providers to help us to communicate with; and
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

Certain of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Inloco will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

  • Conform under a duty to disclose or share your personal data in order to comply with a legal or regulatory obligation or request;
  • Enforce or apply our Terms and other agreements or to investigate potential breaches;
  • Protect and defend the rights or property of Inloco; and
  • Act under exigent circumstances to protect the personal safety of users of Inloco or the public.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Any data deemed no longer relevant is deleted.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for analytical, research, user reviews and recommendations, or statistical purposes and to help us improve the Site and services. As this is no longer personal data we may use this information indefinitely without further notice to you.

9. Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We aim to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this privacy policy

Inloco will from time to time update this privacy policy to reflect company and user feedback and any changes in data protection regulations.  Inloco encourages you to periodically review this privacy policy to be informed of how Inloco is protecting your information.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Inloco Privacy Policy

Effective date: 1 June 2020

Our commitment to you

At Inloco, your privacy is a top priority. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly. We do not compromise your privacy and we have designed and built Inloco with your privacy in mind. We strive to be transparent in the way we process your data and to communicate with you clearly, so you can easily understand the data we collect, why we collect it and what we do with it. 

Introduction

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Site” means the webapp and the website www.myinloco.com, including all Services made available via the webapp and the website.

Contents

1. Important Information and who we are

Purpose of this Privacy Policy

This privacy policy aims to give you information on how we collect, use, process and disclose your personal information, in conjunction with your use of Inloco. By using and interacting with the Site, you consent to us processing your personal data in accordance with this privacy policy. If you see an undefined term in this privacy policy, it has the same definition as in the Terms of Use.

Inloco is not directed to children under 15 years, our minimum childcarer age is 15 and we do not knowingly collect data relating to children under 15 years. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

You are responsible for the type, detail and nature of the information that you choose to put on your profile and/or other information that you share with other users. Please consider carefully the information that you choose to share with others.  As stated in the Terms of Use, you are also responsible for the security of your profile by ensuring that you have a robust and unique password, that you do not share it with anyone and that you notify Inloco promptly with any security concern. We will not be liable for any unauthorised transactions or activity entered into using your name and password.

Controller

My Inloco Limited is the data controller and responsible for your personal data (collectively referred to as ”Inloco”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO  in the following ways:

Mail: My Inloco Ltd, Needlemakers, Watts Green, Chearsley, Bucks, HP18 0DD

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Information that is necessary for the use of the Inloco platform

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about others that you provide to us with, including (but not limited to) information that you provide by completing your profile or by creating a booking on the Site.  You represent and warrant to us that you have obtained the express consent from the individuals whose data you provide us with.  For the avoidance of doubt, any reference in this privacy policy to your data shall include data about other individuals that you have provided us with.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, nationality, identity documentation,  profile picture, date of birth and gender.
  • Contact Data includes billing address, home address, email address, telephone number and parent email address if a childcarer is under 18 years old.
  • Financial Data includes bank account and/or payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, services or bookings made or provided by you, membership details, the information you add about yourself to your public profile , schools (if added), your connections and favourites, your preferences, reviews, recommendations, referrals, in app messages, feedback and survey responses.
  • Usage Data includes information about how you use our web app, site and services and details relating to your bookings / booking requests such as, the age, and gender of the children and the booking location.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. This information is used for the operation of the Site and the services provided by Inloco, and to provide general statistics regarding the use of the Site and services.

In the course of providing services to you, we do not collect information that could reveal your (or your childrens) racial or ethnic origins, sexual orientation, political opinions, physical or mental health, religious or philosophical beliefs or trade union membership. Such information is considered Special Categories of Personal Data under GDPR. We would only collect this information where you have given your explicit consent or one of the other exemptions apply (i.e. it is necessary to comply with our legal obligations).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with childcare services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, social media, on our Site or otherwise. This includes personal data you provide when you:

  • sign up and create an account and public profile on our Site;
  • become a member;
  • use the Site and services provided;
  • meet with one of our employees, ambassadors or consultants;
  • request marketing to be sent to you;
  • complete a form on the Site, or in person, requesting us to contact you;
  • enter a competition, promotion or survey;
  • submit an application for a role within Inloco; or
  • make a complaint or give us feedback or contact us.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie policy for further details.

Third parties or publicly available sources

We will receive personal data about you from various third parties and public source as set out below:

  • Technical Data or Usage Data from analytics providers or search information providers; and
  • Employment, Identity and Contact Data from third party recruitment agencies, where relevant.

4. How we use your personal data

We will only use your personal data to operate the Site, the web app and the services you provide or have requested including enabling payment by Childcarers and Families.  Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by updating your preferences in your account settings.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Basis for processing
To register you as a User, create your profile and complete ID verification
  • Identity
  • Contact
  • Profile
  • Performance of a contract with you
To process your booking and services, such as:
  • (a) Manage your payments, membership, in app messaging, reviews and building your network
  • (b) Collect and recover money owed to us
  • Identity
  • Contact
  • Profile
  • Financial
  • Transaction
  • Profile
  • Usage
  • Performance of a contract with you
  • Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, such as:
  • (a) Notifying you about changes to our service, terms or privacy policy
  • (b) Asking you to leave a review
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, fundraising initiative, promotion, competition or complete a survey
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (to study how users use our services, to develop them and grow our business)
To administer and protect our business and Site including:
  • troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
  • Identity
  • Contact
  • Technical
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you:
  • measure or understand the effectiveness of advertising and Site design and services
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Technical
  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Technical
  • Usage
  • Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  • Identity
  • Contact
  • Technical
  • Usage
  • Profile
  • Marketing and Communications
  • Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We may use your personally identifiable information to inform you of other products or services available from Inloco and our partners.

You will only receive marketing communications from us if you have opted in to receive the requested information from us. We do not sell, rent or lease or provide in any other way our users lists to third parties.

We may also contact you via surveys to conduct research about your opinion of our website and services.  

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging in the “communication setting” page of the Site and checking or unchecking relevant boxes to adjust your communication preferences.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and applicable law.

You agree that Inloco may share data with third parties providers. The types of third party service providers whom we share your information with includes:

  • Affiliates of Inloco;
  • Payment providers (including online payment providers and fraud detection providers) for the purposes of providing services to us, for example when they process information such as credit card payments;
  • Childcarers and Families for the purposes of fulfilling the childcare services;
  • Third party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers (including cloud providers) and system administrators, third parties who host and manage data or provide programming or technical support, conduct reference checks on candidates on our behalf;
  • Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services;
  • Third party analytics partners to analyse website traffic and understand user needs and trends or third party marketing service providers to help us to communicate with; and
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

Certain of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Inloco will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

  • Conform under a duty to disclose or share your personal data in order to comply with a legal or regulatory obligation or request;
  • Enforce or apply our Terms and other agreements or to investigate potential breaches;
  • Protect and defend the rights or property of Inloco; and
  • Act under exigent circumstances to protect the personal safety of users of Inloco or the public.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Any data deemed no longer relevant is deleted.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for analytical, research, user reviews and recommendations, or statistical purposes and to help us improve the Site and services. As this is no longer personal data we may use this information indefinitely without further notice to you.

9. Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We aim to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this privacy policy

Inloco will from time to time update this privacy policy to reflect company and user feedback and any changes in data protection regulations.  Inloco encourages you to periodically review this privacy policy to be informed of how Inloco is protecting your information.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.