Privacy Policy
1. Who we are
SmartCare Living is a trading name for the Irish company providing the SmartGuardian home-safety service across Dublin and Leinster. For data-protection purposes we are the data controller for personal data processed via this website and during the supply of our services.
Contact:
SmartCare Living, Dublin, Ireland
Email: info@smartcareliving.ie
Data-protection enquiries: privacy@smartcareliving.ie
Phone: +353 (0) 1 513 0424
2. What data we collect
2.1 Data you give us directly
- Identity & contact: name, phone number, email address, eircode/area, address (for in-home consultations).
- Assessment quiz answers: your responses to the 2-minute online assessment (e.g. your concerns, your loved one's situation, urgency).
- Booking details: the date and time you select for a callback or consultation.
- Free-text messages: anything you write in our contact form.
- Service-relevant data: if you become a customer, the floor plan of the home, sensor placements, emergency-contact details for the household.
2.2 Data collected automatically
- Server access logs: IP address, request timestamp, user-agent string, requested URL. Retained for security, abuse prevention, and rate-limiting purposes (typically 30 days). This is processed under GDPR Article 6(1)(f), legitimate interest in protecting our service.
- Website usage: pages visited, time on page, links clicked, referrer, approximate location (city level), device type, browser. Collected via Google Analytics 4 if you accept cookies.
- Advertising attribution: if you arrived from a Google Ads click, we receive a
gclid(Google click ID) so we can measure which ads work. Subject to your cookie consent. - Cookies and similar: see our Cookie Policy.
2.3 Data the SmartGuardian service generates (customers only)
- Anonymised stick-figure movement data (no video is recorded).
- Detected events (e.g. fall, prolonged inactivity, "help me" voice command).
- Notification logs (who was notified, when, by what channel).
The SmartGuardian system uses on-device privacy-preserving processing, no camera footage is recorded or stored at any point.
3. Why we use your data (legal basis under GDPR Art. 6)
| Purpose | Legal basis |
|---|---|
| Responding to your enquiry, sending you the assessment recommendation, scheduling your callback or home consultation | Performance of a contract / pre-contractual steps (Art. 6(1)(b)) |
| Following up by phone, email or SMS where you've given us your details | Legitimate interest in providing the service you asked for (Art. 6(1)(f)) |
| Operating the SmartGuardian service for paying customers | Performance of a contract (Art. 6(1)(b)) |
| Measuring website performance, ad effectiveness, retargeting | Your consent via the cookie banner (Art. 6(1)(a)) |
| Complying with our legal obligations (tax, consumer protection, data-protection) | Legal obligation (Art. 6(1)(c)) |
| Defending or pursuing legal claims | Legitimate interest (Art. 6(1)(f)) |
3.1 Health-related answers in the assessment quiz (special-category data under GDPR Art. 9)
The assessment quiz asks you a small number of questions about your (or your relative's) recent falls, mobility, living situation, and prior safety equipment. Some of those answers are "data concerning health" under GDPR Article 4(15), which means they're treated as special-category data under Article 9 and need a stronger legal basis than ordinary personal data.
Before you can submit the quiz, you tick an unticked consent box that says:
"I understand that the answers above relate to my (or my relative's) health, and I explicitly consent to SmartCare Living processing this information to recommend a service tier and contact me about it. I can withdraw this consent at any time by emailing privacy@smartcareliving.ie."
That ticked box is your explicit consent under Art. 9(2)(a), which is the lawful basis we rely on for the health-related part of the quiz. We record the consent text, version, and timestamp alongside your lead record so we can demonstrate it under Art. 7(1) if you ever ask us to.
Two important points about that consent:
- It's optional. If you don't tick it, the quiz won't submit and we won't receive your answers. You can still contact us directly via the contact form or phone — we just can't run the quiz-based recommendation engine without your express permission to handle the health-related answers.
- You can withdraw it at any time. Email privacy@smartcareliving.ie and we will delete the health-related answers (and, if you ask, the rest of your lead record) without undue delay. Withdrawal does not affect anything we lawfully did before you withdrew.
We use the quiz answers to (a) recommend a service tier on your results page, and (b) brief our specialist before they call you. We do not use them for marketing, profiling for third parties, or any automated decision with legal or significant effect on you (see §10).
4. Who we share data with
We never sell your personal data. We share it only with the service providers listed below, each acting as a data processor on our behalf under a written contract:
| Provider | What they do | Where data is stored |
|---|---|---|
| Vercel | Website hosting and serverless functions | EU + USA (under EU−US Data Privacy Framework) |
| Resend | Sending lead-notification emails to us and confirmation emails to you | EU + USA |
| Calendly | Scheduling callbacks and home consultations | USA (under EU−US Data Privacy Framework) |
| Twilio | SMS notifications to our team when you submit a lead | EU + USA |
| Stripe | Payment processing and subscription billing for SmartGuardian customers | EU + USA (under EU−US Data Privacy Framework) |
| Google Workspace, Google Sheets | Internal lead tracking and email | EU |
| Google Analytics 4 & Google Ads | Website analytics and advertising effectiveness (if you accept cookies) | EU + USA |
| Google Tag Manager | Loading the analytics and advertising tags above | EU + USA |
For transfers outside the European Economic Area (EEA), we rely on EU Standard Contractual Clauses, the EU−US Data Privacy Framework, or other lawful transfer mechanisms.
We may also disclose your data where required by law (e.g. court order, regulator request) or to protect our legal rights.
5. How long we keep it
- Lead enquiries (no purchase): up to 24 months from last contact, then deleted from active systems.
- Customer records: for the duration of your service plus 7 years afterwards (Irish Revenue requirements for invoicing).
- SmartGuardian event data (customers): retained for 90 days for service improvement and dispute resolution, then deleted unless retained for a specific safety incident.
- Website analytics: Google Analytics retains event data for 14 months by default.
- Cookie consent record: stored in your browser's
localStorageuntil you clear it or change your decision.
6. Your rights under GDPR
You have the right to:
- Access the personal data we hold about you
- Ask us to correct data that is wrong or incomplete
- Ask us to delete your data ("right to be forgotten"), subject to legal retention requirements
- Ask us to restrict our processing while a dispute is resolved
- Receive a copy of your data in a portable format (data portability)
- Object to processing based on legitimate interest, including direct marketing
- Withdraw consent for cookies or marketing emails at any time, without affecting prior lawful processing
- Lodge a complaint with the Data Protection Commission of Ireland: dataprotection.ie · 21 Fitzwilliam Square South, Dublin 2, D02 RD28
To exercise any of these rights, email privacy@smartcareliving.ie. We'll respond within one month and will not charge a fee unless your request is manifestly unfounded or excessive.
7. Marketing communications
If you submit a lead form on this website, we may contact you by phone, email or SMS to follow up on the specific enquiry you made. This is part of providing the service you asked for, not generic marketing.
We will not add you to any marketing newsletter or send you unrelated promotional content unless you specifically opt in. If we ever do, every email will include a one-click unsubscribe link.
8. Children
Our website and services are designed for adults arranging care for elderly relatives. We do not knowingly collect personal data from anyone under 16. If you believe we hold data about a child, please contact privacy@smartcareliving.ie and we will delete it.
9. Security
We protect your data with industry-standard measures: HTTPS encryption everywhere, hashed credentials, role-based access for our team, encrypted backups, supplier vetting, and regular security reviews. No system is perfectly secure, if we ever experience a personal-data breach that is likely to result in a risk to you, we will notify the Data Protection Commission within 72 hours and you directly without undue delay, as required by GDPR Art. 33−34.
10. Automated decision-making
The SmartGuardian system uses AI to detect movement events from sensor data, but no decision with legal or significant effect on you is made solely by automated means. A human being decides whether to act on any notification.
Our online assessment quiz produces a recommended product tier ("low / moderate / high / urgent"). This is a non-binding suggestion that helps us prepare for our follow-up call, it is not a clinical risk assessment, and it does not bind us or you to any particular product or pricing. You can review our full product disclaimer for the medical-device limitations of our service.
11. International transfers
Some of our service providers (e.g. Calendly, Twilio in some configurations) are based in the United States. Where personal data leaves the EEA, we rely on:
- The EU−US Data Privacy Framework certification of the recipient, where applicable
- EU Standard Contractual Clauses for other transfers
- Where neither applies, we either find an EU-only alternative or seek your explicit consent before transferring
12. Changes to this policy
If we make material changes, we'll update the "Last updated" date at the top and (for active customers) send you an email or in-app notice with reasonable advance notice. Minor wording or contact-detail changes won't trigger a notice.
13. Related documents
- Cookie Policy, what cookies we use and how to control them
- Terms of Use, rules for using this website
- SmartGuardian Disclaimer & Legal Notice, what the SmartGuardian product does and does not do, and our liability position