Vulnerability Initiative – Terms and Privacy Statements

Terms

Please read these Terms and Conditions carefully and ensure that you understand them before using Our Site. These Terms and Conditions, together with any other documents referred to herein, set out the terms of use governing your use of this website, https://healthyhomessolutions.co.uk/

Your agreement to comply with these Terms and Conditions is indicated by your use of Our Site. If you do not agree to these Terms and Conditions, you must stop using Our Site immediately.

The following document[s] also apply to your use of Our Site:

Our Privacy Policy, available at Privacy Policy. This is also referred to below in Part 14.

  • Definitions and Interpretation
    1. In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:

“Content”

means any and all text, images, audio, video, scripts, code,
software, databases, and any other form of information
capable of being stored on a computer that appears on, or
forms part of, Our Site; and

“We/Us/Our”

means Healthy Homes Solutions
  • Information About Us
      1. Our Site is operated by Healthy Homes Solutions. We are a limited company registered in England and Wales under company number 12216394. Our registered address is Unit 3 East Bond Street, Leigh, England, WN7 1BP.
      2. Our VAT number is 360 372 024.
      3. We are regulated by Information Commissioner’s Office (ICO). Registration Number: ZA723327
      4. We are a member of Housing Associations’ Charitable Trust (HACT).
      5. We are a financial services company, that for the past 10+ years, have been developing a full end-to-end and modular profiling, targeting and householder engagement platform. The platform provides a tailored service for Housing Associations, Local Authorities, Managing Agents and Partners to identify and target the homes relevant to their specific programme needs.
  • How to Contact Us

To contact Us, please email Us at info@healthyhomessolutions.co.uk or telephone Us on 0800 151 3014.

  • Access to Our Site
      1. Access to Our Site is free of charge.
  • Changes to Our Site

We may alter and update Our Site (or any part of it) at any time.

  • Changes to these Terms and Conditions
      1. We may alter these Terms and Conditions at any time. As explained above, your use of Our Site constitutes your acceptance of these Terms and Conditions. Consequently, any changes made to these Terms and Conditions will apply to your use of Our Site the first time you use it after the changes have been implemented.
      2. If any part of the current version of these Terms and Conditions conflicts with any previous version(s), the current version shall prevail unless We explicitly state otherwise.
  • How You May Use Our Site and Content (Intellectual Property Rights)
      1. All Content included on Our Site and the copyright and other intellectual property rights in that Content belongs to or has been licensed by Us, unless specifically labelled otherwise. All Content is protected by applicable United Kingdom and international intellectual property laws and treaties.
      2. You may access, view, and use Our Site in a web browser (including any web browsing capability built into other types of software or app) and you may download Our Site (or any part of it) for caching (this usually occurs automatically).
      3. You may print one copy and download extracts of any page(s) from Our Site for personal use only.
      4. You may not modify the printed copies or downloaded extracts in any way. Images, video, audio, or any other Content downloaded from Our Site must not be used separately from accompanying text.
      5. Our status as the owner and author of the Content on Our Site (or that of identified licensors, as applicable) must always be acknowledged.
      6. You may not use any Content [saved or downloaded] from Our Site for commercial purposes without first obtaining a licence from Us (or our licensors, as applicable). [This does not prevent the normal access, viewing, and use of Our Site for general information purposes by business users or consumers.]]
  • Links to Our Site
      1. You may link to Our Site with our express written permission.
      2. Links to Our Site must be fair and lawful. You must not take unfair advantage of Our reputation or attempt to damage Our reputation.
      3. You must not link to Our Site in a manner that suggests any association with Us (where there is none) or any endorsement or approval from Us (where there is none).
      4. Your link should not use any logos or trade marks displayed on Our Site without Our express written permission.
      5. [You must not frame or embed Our Site on another website without Our express written permission.]
      6. [You may not link to Our Site from another website the main content of which is unlawful; obscene; offensive; inappropriate; dishonest; defamatory; threatening; racist, sexist, or otherwise discriminatory; that promotes violence, racial hatred, or terrorism; that infringes intellectual property rights; or that We deem to be otherwise objectionable.]
  • Links to Other Sites
      1. Links to other websites may be included on Our Site. Unless expressly stated, these sites are not under Our control. We accept no responsibility or liability for the content of third-party websites.
      2. The inclusion of a link to another website on Our Site is for information purposes only and does not imply any endorsement of that website or of its owners, operators, or any other parties involved with it.
  • Disclaimers
      1. Nothing on Our Site constitutes professional advice on which you should rely. It is provided for general information purposes only.
      2. We make reasonable efforts to ensure that the Content on Our Site is complete, accurate, and up to date, but We make no warranties, representations, or guarantees (express or implied) that this will always be the case.
      3. If you are a business user, We exclude all implied representations, warranties, conditions, and other terms that may apply to Our Site and Content.
  • Our Liability
      1. Nothing in these Terms and Conditions excludes or restricts Our liability for fraud or fraudulent misrepresentation, for death or personal injury resulting from negligence, or for any other forms of liability which cannot be lawfully excluded or restricted.
      2. If you are a business user (i.e. you are using Our Site in the course of business or for commercial purposes), to the fullest extent permissible by law, We accept no liability for any loss or damage, whether foreseeable or otherwise, in contract, tort (including negligence), for breach of statutory duty, or otherwise, arising out of or in connection with the use of (or inability to use) Our Site or the use of or reliance upon any Content included on Our Site.
      3. If you are a business user, We accept no liability for loss of profit, sales, business, or revenue; loss of business opportunity, goodwill, or reputation; loss of anticipated savings; business interruption; or for any indirect or consequential loss or damage.
      4. [Our Site is intended for non-commercial use only.] If you are a consumer, you agree that [you will not use Our Site for any commercial or business purposes and that] We shall have no liability to you for any business losses as set out above.
  • Viruses, Malware, and Security
      1. We exercise reasonable skill and care to ensure that Our Site is secure and free from viruses and malware; however, We do not guarantee that this is the case.
      2. You are responsible for protecting your hardware, software, data, and other material from viruses, malware, and other internet security risks.
      3. You must not deliberately introduce viruses or other malware, or any other material which is malicious or technologically harmful either to or via Our Site.
      4. You must not attempt to gain unauthorised access to any part of Our Site, the server on which Our Site is stored, or any other server, computer, or database connected to Our Site.
      5. You must not attack Our Site by means of a denial of service attack, a distributed denial of service attack, or by any other means.
      6. By breaching the provisions of Parts 12.3 to 12.5, you may be committing a criminal offence under the Computer Misuse Act 1990. Any and all such breaches will be reported to the relevant law enforcement authorities and We will cooperate fully with those authorities by disclosing your identity to them. Your right to use Our Site will cease immediately in the event of such a breach.
  • Acceptable Usage of Our Site
      1. You may only use Our Site in a lawful manner:
        • You must ensure that you comply fully with any and all local, national, or international laws and regulations that apply;
        • You must not use Our site in any way, or for any purpose, that is unlawful or fraudulent; and
        • You must not use Our Site to knowingly send, upload, or in any other way transmit data that contains any form of virus or other malware or any other code designed to adversely affect computer hardware, software, or data of any kind.
      2. If you fail to comply with the provisions of this Part 13, you will be in breach of these Terms and Conditions. We may take one or more of the following actions in response:
        • Suspend or terminate your right to use Our Site;
        • Issue you with a written warning;
        • Take legal proceedings against you for reimbursement of any and all relevant costs on an indemnity basis resulting from your breach;
        • Take further legal action against you, as appropriate;
        • Disclose such information to law enforcement authorities as required or as We deem reasonably necessary; and/or
        • Any other actions which We deem reasonably appropriate (and lawful).
      3. We hereby exclude any and all liability arising out of any actions that We may take (including, but not limited to those set out above in Part 13.2) in response to your breach.
  • How We Use Your Personal Information

We will only use your personal information as set out in Our Privacy Policy, available from https://healthyhomessolutions.co.uk/privacy-policy/ [and Our Cookie Policy, available from https://healthyhomessolutions.co.uk/cookie-policy/].

  • Communications from Us
      1. If We have your contact details, We may send you important notices by email from time to time. Such notices may relate to matters including, but not limited to, changes to Our Site or to these Terms and Conditions.
      2. We will not send you marketing emails without your express consent. If you do consent to marketing, you may opt out at any time. All marketing emails from Us include an unsubscribe link. If you opt out of emails from Us, it may take up to 1 week for your request to take effect and you may continue to receive emails during that time.
      3. For questions or complaints about communications from Us, please contact Us using the details above in Part 3.
  • Law and Jurisdiction
    1. These Terms and Conditions, and the relationship between you and Us (whether contractual or otherwise) shall be governed by, and construed in accordance with, English law.
    2. If you are a consumer, you will benefit from any mandatory provisions of the law in your country of residence. Nothing in Part 16.1 takes away from or reduces your legal rights as a consumer.
    3. If you are a consumer, any dispute, controversy, proceedings, or claim between you and Us relating to these Terms and Conditions or to the relationship between you and Us (whether contractual or otherwise) shall be subject to the jurisdiction of the courts of England, Wales, Scotland, or Northern Ireland, as determined by your residency.
    4. If you are a business user, any dispute, controversy, proceedings, or claim between you and Us relating to these Terms and Conditions or to the relationship between you and Us (whether contractual or otherwise) shall be subject to the exclusive jurisdiction of the courts of England and Wales.


Privacy Policy

As the operator of this website and the provider of the additional services to the Vulnerability Registration Service (VRS) members, Healthy Homes Solutions Ltd (HHS, us, we, our) is what is known as the “data controller” of personal data that it collects. This is because we decide why certain types of information are collected and how they are handled. As a data controller we are registered with the Information Commissioner’s Office, the authority in charge of data protection in the UK, under registration number ZA723327.

Looking after personal data is important to us, we want to give you as much information as possible about how we use your data and why. We also want you to know that you can reach out to us if you want to know more about how we look after your personal data, so please feel free to contact us at info@hhsvrs.org.

What is “personal data”?
“Personal data” means any information about you or that could be used to identify you. This includes your name and contact details, but also information about the device you’re using to access our site. There is more detail about the kinds of information that we use below.

What is “special category data”?
“Special category data” means information about you that is more sensitive, for example because it’s about your health, religion or ethnicity. In order to run our service, we have to process some health data. We may categorize vulnerabilities in this respect and offer a flag system for our users, but don’t collect any other specific details regarding the nature of our service user’s vulnerabilities. To the extent that we do process any health data, we will take extra measures to make sure that this is done safely and legally. We don’t process any other types of special category data.

What is “processing”?
When we talk about “processing”, this is just a legal term for using data and pretty much includes anything that we could do with your personal data. For example, “processing” includes collection, retrieval, organisation, storage, transfers and erasure.

What do we process your data for (purpose of processing) and on what legal basis?
In accordance with the UK`s Data Protection Act (“DPA”) and the General Data Protection Regulation (“GDPR”), the following legal basis, unless specifically described apply to the processing of your Personal Data:

  • you have given your consent (Art. 6 para. 1 lit. a GDPR),
  • the data is necessary for the fulfilment of a contract / pre-contractual measures (Art. 6 para. 1 lit. b GDPR),
  • the data is necessary for the fulfilment of a legal obligation (Art. 6 para. 1 lit. c GDPR) or
  • the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden (Art. 6 para. 1 lit. f GDPR).

How do we collect it?
For our service users, we either collect information from you when you register via the website or from a phone call one of our trusted partner firms where they are registering you on your behalf. 

If you are visiting our website or are acting on behalf of one of our partner firms, then we will only collect data from you when you visit our site, or that you provide to us in connection with providing the service to others.

What types of personal data do we use and why?
We will collect different types of personal data for different reasons depending on who you are. But, we will only use your data where we have a real purpose and a legal basis for doing so. To help make it clear why we use different kinds of data and what the legal bases apply, we have put all of this information into the table below.

 

Types of Personal Data

Purpose

Legal Basis

Service users

• Names
• Address (and length of residence)
• Contact details (email address and telephone number) and preferred contact method
• Gender
• Date of birth
• VRS registration number
• Legal status
• Information related to your financial, familial, legal or other personal circumstances

To register you for the service and to manage
your registration, including setting appropriate
flags for your period of registration

Your consent

 

• Health data

To register you for the service

Your explicit consent

Website users

• IP address
• Website usage data (for more information about how this works please see our Cookie Notice below)

To protect and improve our website

Our legitimate interest in operating our website

Partner firms

• Name
• Employer
• Work location
• Work contact details (email and telephone number)
• Contact history with us
• Account login details and password

To allow you to access the service or
provide it to others and to manage our
relationship with you

To keep in touch with you regarding
 use of the service

Our legitimate interest in providing and maintaining the service

How does consent work?

For service users registering for our service, we will only process your data where we have your explicit consent to do so. Equally, we will only allow others to see your registration where you have explicitly consented to that. In any case where you have provided your consent, you can always withdraw it at any time by contacting us and letting us know.

However, it’s important for you to understand that withdrawing your consent does not affect the lawfulness of processing already done on that basis. Equally, if you do withdraw your consent, then we would have to remove you from the register meaning that unfortunately you would no longer be able to use our service.

Integration of third-party services and content

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (hereinafter uniformly referred to as “content”). 

This always requires that the third-party providers of this content are aware of your Personal Data including your IP.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:

Marketing and Notifications: Twillio (SMS) and Mailchimp by Intuit Inc (E-Mail)

How we share information and data?

In the course of our business operations, we may disclose your personal data by transmission to third parties and, where applicable, to so-called third countries outside the UK and the EEA. Where we transfer data to third parties, we ensure a system of adequate protection mechanism and so-called “processing agreement” is signed with them. We will not disclose or otherwise distribute your personal data to third parties unless this:

  • is necessary for the performance of our services, 
  • you have consented to the disclosure,
  • or the disclosure of data is permitted by relevant legal provisions. 

However, we are entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors within the framework of the DPA and GDPR. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations. 

The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with the DPA and GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organisational measures, and additional controls by us.

We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil our legitimate interests.

These are assisted by the following third parties:

  • Healthy Homes Solutions Limited (Company Number 12216394)
  • Totem Marketing Ltd (Company Number 07913949)
  • Daida Limited (Company Number 13866438) Our Sister Company Daida for propensity modelling, statistics and industry help.
  • Merinal Ltd (Company Number 06521381)
  • Welfare Together Limited (14449818)
  • Cadent, SGN, Northern Gas and Wales and West Utilitiws – Priority service register (PSR), this will only be shared upon customer consent for wanting to join the PSR.
  • MR Digital Ltd (10485670) – for all system development 
  • Telephone Preference Service (TPS), this will only be shared upon customer consent for wanting to join the TPS.
  • Royal Mail – We share names and address details to allow them to deliver our marketing material letters, brochures and any other material needed e.g., Carbon monoxide monitors. 

Connected for warmth, to qualify for you for the First-Time central heating grant.

Will you send my personal data to other countries?
All of the personal data we handle is stored in the UK, we’ll never send your data to recipients located in other countries.

How do we keep your data secure?
We have implemented appropriate technical and organisational measures to ensure that we are doing everything that we can be in order to protect the security of your data. We regularly review our internal policies, procedures and technical security to ensure that they remain appropriate to the risks of your data being compromised in any way.

How long will we keep your data?
Generally, we only keep your information for as long as necessary to achieve the purposes for which it was initially collected. However, if data has been collected in connection with contractual commitments, then we will store associated data for 6 years after the ending of the contractual relationship, at which time it will be reviewed and if no longer necessary then it will be permanently deleted.

In some cases, we may anonymise data for statistical purposes. Where we do this we make sure that you can’t be identified by the information we keep, meaning that it’s no longer personal data and can be kept for a longer period.

What is “automated decision making” and do we do it?
Automated decision making is where a decision is made about you or you are profiled without human involvement in that process, and where that has a legal or other significant effect on you. We don’t do any automated processing, so you never need to worry about decisions being made in this way.

Do you have rights and, if so, what are they?
We want you to know that you have rights under data protection laws in connection with our use of your data. These don’t apply in every case and can be complicated, but to help we have included some general information on what these rights mean in the table below.

Direct marketing in the context of a customer relationship
Insofar as you have also given us your separate consent to process your data for consulting, marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

Advertising and Marketing
Insofar as you have also given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.  

Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

Withdraw your consent
You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request to us using. Should you withdraw your consent to the collection, use or disclosure of your Personal Data, it may impact our ability to proceed with your transactions, agreements, or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

Third Party Policies
Our website may, from time to time, contain links to and from the websites of our partner networks, business partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Data to these websites. 

Social Media
We are present in social on the basis of our legitimate interest. If you contact us via those social media platforms, you should note that the chat history can neither be deleted by us nor by you. And that, in accordance with the DPA and GDPR, the relevant social media platform and we are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. A Joint Controller Agreement itself if very legalistic and lengthy, but in a nutshell, it clarifies how the jointly responsible parties will fulfil the obligations arising from data protection laws that are applicable to them. 

Further, your use of the relevant social media platform and its functions is your own responsibility, this applies in particular to the use of the interactive functions (e.g., commenting, sharing, rating). In addition, the relevant social media platform may use your data for market research, advertising purposes and to create profiles about your usage behavior and your interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. we, as the provider of this policy, do not collect and process any data from your use of the relevant social media platform beyond the point of responding to your requests and if so intended, entering into a contract with you. For further information about the relevant social media platforms use of your Personal Data, please refer to their Privacy Policies.

The legal basis for the use of the relevant social media platform is our legitimate interest, your consent or, in the case of a (pre) contractual relationship with us, the initiation of a contractual service.

What is my right?

What does that mean?

Access

You can ask that we provide copies of your personal data that we are processing

Rectification

If any of the data that we hold about you is inaccurate or incomplete, then you can ask us to fix that

To be forgotten

You can ask us to delete the data that we hold about you

Restriction of processing

Sometimes you can ask us to stop using your data in a certain way, for example if the data we hold is inaccurate and needs to be corrected before being used again

Object to processing

In some circumstances you can object to the way that we use your data

Data portability

Where we hold your data other than in paper files and processing is based on your consent, you can ask us to transfer your data to another data controller

What if we update this notice?

We want to be able to provide you with the most accurate information about how we process your personal data and also accept that laws and regulations change over time. To make sure that we continue to provide the best information and so that we can be sure that we are complying with the law, we might need to change this notice from time to time and reserve the right to make those changes. However, if we do change any part of this notice and that affects you, then we will get in touch to let you know.

Questions or complaints?
If you have any questions at all about this notice or how we handle your personal data then you can always contact us at info@healthyhomessolutions.co.uk . We hope that you never have cause to complain about the way we handle your data, but you can always do so by contacting the Information Commissioner’s Office (ICO) online here or by telephone at 0303 123 1113.

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