LifeCurve™ UK App
Privacy Notice –
July 2025

Glossary

Data: Information which can be used to identify a specific individual person.

Processing: any action involving personal data – including working with the data in some way as well as collecting, storing, sharing and deleting the data.

Controller: the person or organisation who determines what data is to be processed, and the purpose for which it is processed. For the purposes of this notice, ADL Smartcare holds this role. Where a partner organisation you are connected to downloads or saves any data available to them, then this organisation becomes the sole Controller of such data.

‘You’ or ‘Your’ means the User of the LifeCurve™ UK App.

‘Us’, ‘We’ or ‘Our’ refers to ADL Smartcare: Owner of the LifeCurve™ Software, including the knowledge and code it contains.

Introduction

The LifeCurve™ mobile App is available to all Android and iOS devices in the UK. The purpose of the app is to assist you with your functional ageing journey, and if required, suggest equipment, exercise routines or other resources tailored to you – all without the need to be assessed at home or at a clinic by a Healthcare Professional.

How should I trust it is safe?

The expert advice offered through the LifeCurve™ App has been gathered by panels of Expert Professionals in the Healthy Ageing field (older person Physiotherapists, Occupational Therapists, Nurses etc) – from best practice, experts in Ageing, and related research over the last twenty years. They are intended to replicate the process and clinical reasoning used by a Professional if they were to carry out an assessment in-person. In addition, accurate use of the service is covered by Professional Indemnity Insurance.

Why can we process your data?

In order to facilitate your access and use of the LifeCurve™ App, we ask for your explicit consent to process the required personal data. You may withdraw your consent at any time by contacting ADL Smartcare – however, we will not be able to provide help or advice for your ageing journey without the data above, or your consent.

ADL Smartcare is equally committed to protecting your rights and privacy in respect of your personal data, in accordance with the UK Data Protection Act.

What data about you is collected?

We request the following data about you and/or the person relying on the advice:

• First name/given name
• Surname/family name
• Email address or phone number (to allow you to access your results)
• Year of birth (to allow us to benchmark you against other users, if you wish)
• Postcode (to confirm service/delivery eligibility, and to provide local resources)
• In response to assessments, information regarding health and ability to complete Activities of Daily Living*
• As required by Client-led assessments, information regarding their home environment*

(* optional)

In addition, through assessments of how you are functionally ageing, we will collect information regarding your ability to complete activities of daily living. This may include information regarding your health, home environment and ability to complete specific tasks or movements. We consider this to be sensitive health information, and so we ask for your explicit consent in order for us to collect and process it.

May I remain anonymous?

No, it is not possible for you to complete a LifeCurve™ assessment, or find out where you are on your ageing journey without providing any personal information identifying you.

What do we do with your data?

Information you have given us in an assessment will be used by our software algorithms to generate the best solutions for you based on healthcare professional assessments processes, knowledge and expert practice recommended to us over twenty years. This is known as Automated Decision Making, and by consenting to using the app you acknowledge your personal data will be subjected to this process. However, it is for you to decide whether you accept the outcome and any suggested movement routines, equipment or other help (which has itself been reasoned by professionals) offered.

We will only ever ask questions relevant to the assessment or goal you’re hoping to complete, thus minimising the data gathered.

You have the option to consent for your anonymised data to be used for the purposes of research into healthy ageing, to improve ageing and wellbeing in future. Declining to opt-in will not affect your rights or ability to use our app for your own healthy ageing journey.

You also have the option to connect to a specific partner or organisation. In doing so, you consent to your data being made available to this third party:

• Your data may be available to authorised employees of the third party who may use it to support you on your ageing journey. It may be possible for them to link the information you provide to other health records they hold. Where this is the case, we require employees to handle your data securely and professionally, inline with their training.
• Your anonymised data may also be used by the third party to provide insight into how the people in your region as a whole are ageing. However, no personally-identifiable data will be shared with any other person or organisation.
• Connecting to the third party may allow you to access additional support, specifically for the locality you have connected to.
• For more information, please refer to the partner’s specific Privacy Notice.

How will your data be kept and stored?

Your data will be stored in the UK by ADL Smartcare on our secure cloud-based infrastructure. ADL Smartcare outsources IT/Data Support and hosting to organisations which are compliant and certified with Cyber Essentials and/or ISO 27001.

In addition, there are a number of physical and technical features built into the LifeCurve™ App and other aspects of our infrastructure and environment, to ensure your data is secure when kept by us.

Your data will be retained for seven years following the last recorded activity (such as an assessment).

To aid the management and administration of the service, from time to time it is necessary for specific employees within ADL Smartcare to have brief access to your data. Where this does happen, your data will also be protected by, and handled in accordance with, the UK’s Data Protection Act (2018). This includes an expectation that our employees will handle your data with due security, confidentiality, care and respect. It is supported by staff training and technical and organisational measures.

Your rights concerning your data

You have a number of rights relating to your data or how we use it:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

If you would like to exercise any of these, or would like a copy of the data we hold about you, please get in touch with ADL Smartcare using the email address below. However, please note that some of these rights aren’t absolute - for example, we may not be able to forget you entirely where we are required by law to retain your data for a specific reason or length of time.

In addition, if you are concerned your data is inaccurate, you may update it on the app yourself or contact support@adlsmartcare.com in the first instance.

If you have a complaint regarding how your data has been handled by us, please first raise this with ADL Smartcare’s Data Protection Officer. If you are not satisfied with the outcome of this, you may escalate your complaint to the Information Commissioner’s Office. For more information, visit: https://ico.org.uk/make-a-complaint/

ADL Smartcare: Electric Works, Sheffield Digital Campus, 3 Concourse Way, Sheffield S1 2BJ

Registered in England: Company 4456225

Email: privacy@adlsmartcare.com