This privacy notice aims to give you information on how Eevi collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service or get in touch with us.

The app is not intended for use by children under 13. However, children’s data may be processed via smart devices. See our Children’s Privacy Statement for more details From time to time, we may make changes to this policy (for example to keep pace with best practices or changes in legislation) so we suggest that you check back every now and again to make sure you are happy with any changes.

You should read this policy in conjunction with our terms and conditions (both for the use of our website and the services we provide) as well as, in the case of our customers, any other terms we may provide you that relate to our services.

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

Full name of legal entity: Total Care and Support Limited a company incorporated and registered in England and Wales. company number 04462867. Our registered office address is Time Technology Park, Blackburn Road, Simonstone, Burnley, United Kingdom, BB12 7TW.

Email address: dataprotection@totalcaresupport.com

Postal address: Time Technology Park, Blackburn Road, Simonstone, Burnley, United Kingdom, BB12 7TW

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

We keep our privacy notice under regular review. This version was last updated on May 2025

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.

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 notice of every website you visit.

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 you which we have grouped together as follows:

• Identity Data may include first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data may include billing address, delivery address, email address and telephone numbers.
• Call Recordings may include contact data, financial data and general queries regarding our services.
• Financial Data may include bank account and payment card details.
• Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data may include 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 may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 or otherwise. This includes personal data you provide when you:
  • enquire about our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • give us feedback or contact us.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • We may also receive information from other telecommunications providers which is required to enable us to provide services to you;
  • From our other group companies regarding information about our services.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Technical Data from the following parties:
  1. analytics providers such as Google;
  2. advertising networks; and
  3. search information providers.

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

We will only use your personal data when the law allows us to. 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 obligation.

See Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

We do not currently use personal data to make solely automated decisions that produce legal or similarly significant effects.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email, text message, letter or by telephone. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of the ways we may 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.

We may also use your information for other lawful purposes. In some instances, we may seek your express and informed consent, where this is required. In other, very limited circumstances, we may use your information where we have a legitimate reason for doing so or in where we are required to use your data to comply with legal and/or regulatory obligations that are imposed upon us.

When you purchase a product through us, our partners may deliver the applicable services related to your product. These services relate to Smart Home products which include and are not limited to door cameras, outdoor and indoor cameras, door sensors, intelligent door handles, temperature and humidity sensors, panic alarms, light switches, socket adapters, heating controls and smart speaker devices with inbuilt listening services.

Where you connect compatible smart devices, we may process data including video, audio or sensor logs. See our Children’s Privacy Statement for more details

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Our marketing can include the following of methods, email, SMS, letter or telephone. If you wish to change your marketing preferences you can easily opt out by:

• Clicking the unsubscribe links on any marketing message.
• Sending an email to dataprotection@totalcaresupport.com

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

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).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We do not sell your data to any third party and would get your express opt-in consent before we share your personal data with any third party out with our group companies for marketing purposes.

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 www.eevi.com/cookie-policy

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.

When we share your information with third parties, they will process your information as either a data controller or as our data processor and this will depend on the purposes to share your personal data with such third party.

We will only share your personal data in compliance with the applicable data protection laws and regulatory requirements.

We may share your personal data for the following reasons set out below:

• Processing direct debits or card payments.
• Debt recovery organisations or legal advisors for the purposes of recovering money that you may owe us.
• Law enforcement agencies in response to properly made requests relating to the prevention and detection of a crime, for the purpose of safeguarding national security or when the law requires us to.
• Providing information in circumstances where we are required to respond to properly made requests from regulatory bodies, including and not limited to the Information Commissioner’s Office, OFCOM and the Health and Safety Executive.
• 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.
• Providing information to banks, building societies or credit card companies regarding transactions relating to your account, including but not limited to responding to charge back claims or claims made under the Direct Debit guarantee.
• Trusted partners which may include advisors, contractors and partner companies to offer the best products and experience to our customers.
• Other group companies, including subsidiaries for the purpose of providing or administrating services.

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

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring the appropriate safeguards are implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers outside the UK or EU/EEA, we use the UK IDTA or UK Addendum to the EU Standard Contractual Clauses where appropriate.

Should these occasions arise, we will ensure that your personal data is not shared until a contract is in place that ensures the personal data is adequately protected and that appropriate measures are in place.

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.

We will only retain your personal data for as long as reasonably necessary and in line with our retention policy 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.

By law we have to keep certain information about our customers for a set period which may include Contact, Identity, Financial and Transaction Data for legal obligations.

Details of the types of data and retention is detailed in the table below, full retention policy is available on request.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We want to make sure you are aware of your rights in relation to the information and/or data that we process about you. We have described those rights and the circumstances in which they apply:

• 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.
• Request to withdraw consent: 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.
• Request not to be subjected to automated decisions: You have the right to require human intervention where it produces legal effects or significantly affects you.

If you wish to exercise any of the rights set out above, please contact us by

• Sending an email to dataprotection@totalcaresupport.com

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.

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 anyperson 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.

We try 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.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.