Intelesant (Howz) provide a service using data from sensors in your home which we share with you via an app or webportal account you have created. We provide a support service through phone or email to provide updates about your installation site and your data. We dispatch sensor kits to your delivery address in order to use our service.
We have carried out a 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.
You are the data owner. We are data controllers which means we decide how your information is processed, but we require your permission to collect and use your data. We consider information in 3 parts personal, pseudonymised and anonymised. Personal information means details that can identify you eg name, address, phone number, pseudonyised means a label is used to name your data which does not identify you but we can link to your identity, and anonymised means any personal identifying information is removed from the data entirely including any links.
Our legal basis for collecting and working with this information is:
- To allow us to provide the Howz service and ensure you receive information for the correct site
- To allow us to offer support services via our telephone and online contact
- To enable you to share your information with others as you wish
Information we collect from you about you
You may be registered with Howz directly as the customer for monitoring in your house or as an Important Person.
To purchase (with or without discount coupon) Howz you are required to give us your first name, surname, email address, home address, delivery address, and site address, and a contact telephone number. Your payment details are collected and stored by third party services –Stripe, Paypal, FreeAgent or GoCardless. Howz have no access to your payment details.
To register with the Howz system you are required to give us your email address, create a user ID and a password, and the town nearest to the installed site. You cannot change your username. Howz requires consent to email you directly with any service issues, changes to the system, changes detected in your data, and data summary reports.
The information you collect is your responsibility and Intelesant has no responsibility for or control over the access to the content, information or data that you generate through use of Howz.
If you contact us we may keep a record of that correspondence.
Information we collect about you and your device
Every time you use Howz we may automatically collect information about the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system and time zone setting.
We also collect details of how you use Howz on the app or webportal.
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 anytime via https://my.howz.com.
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 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 personal information is stored within a system called Zendesk which is fully encrypted and only accessible to those who deal with customer service. Your personal information from the purchase is stored on an encrypted server provided by Nettl and this is only accessible by customer service staff within Intelesant. The link between your site and your personal information is stored on our secure server in a fully encrypted database.
Whilst Howz is open, data is stored on your device. 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
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
Usernames and email addresses are used to uniquely identify you in Howz. They can be the same as your email address if you choose but do not have to be.
Your username must be linked to an email. This is so that we have a way of contacting you or to help you reset your password if you have forgotten it. Please keep your username and 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 username to another email address at any time.
Making changes and deactivating or deleting your account
You may deactivate or delete your account or remove messages from your Timeline by contacting Howz customer service as directed on the www.howz.com website or via telephone 0161 226 5353.
You can remove a Very Important Person at any time.
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 Important People 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).
We are constantly striving to improve functionality on this site through technology changes. This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy, will be notified in this Supplement at the time of the change.
Links to third party websites
If you have questions or complaints regarding our use of your information and your privacy please contact us by email at firstname.lastname@example.org
What if you have a complaint?
How to contact us
You can contact us by clicking here.
Version 4.1 updated May 2018