Privacy Policy

1. About this policy

This policy explains how we collect, use, and protect personal data when you use AirCarers Companion. AirCarers Companion is help before care, connecting families with vetted self-employed companions to support older people at home.

AirCarers Companion does not provide personal care or any other regulated activity within the meaning of the Health and Social Care Act 2008.

For the purposes of UK data protection law, Aircarerscompanion Ltd is the "controller" of the personal data we process about you.

You can contact us about this policy at any time at lucie@aircarers.co.uk.

Our data protection advisor: we are not legally required to appoint a Data Protection Officer, but we have engaged James Haigh (Murrayfield Solicitors) as our data protection advisor. You can contact him at james@aircarers.co.uk.

ICO registration: Aircarerscompanion Ltd is registered with the UK Information Commissioner's Office under registration number [ICO REGISTRATION NUMBER PENDING]. Registration is legally effective from the date the ICO received our data protection fee (27 May 2026).

2. Who we are and the people we serve

• Aircarerscompanion Ltd is the platform operator and data controller.
• Companions are self-employed individuals who provide visits through the platform. They are not employees of Aircarerscompanion Ltd.
• Service users are the older adults receiving visits.
• Families are the people who book and pay for visits on behalf of a service user, typically the adult child or another family member.

3. The personal data we collect

We collect the following categories of personal data:

Information you give us directly

• Names, addresses, phone numbers, and email addresses
• Date of birth (where required, e.g. for vetting companions)
• Payment information (handled by Stripe, we do not store full card numbers)
• Information about the care needs of the service user, where you choose to share it (e.g. in the "What's the situation?" field on the callback form)
• Identity documents during companion onboarding (DBS, right-to-work, proof of identity, references, PLI evidence)
• Visit notes written by the companion after each visit

Information collected automatically

• IP address (anonymised, see §6)
• Device and browser type
• Pages visited and interactions with the platform
• GPS location data when a companion checks in and out of a visit

Information from third parties

• Companion DBS check results from our DBS umbrella body
• Reference responses from referees nominated by companions

4. How and why we use your data

We use your personal data for the following purposes, on the following lawful bases under UK GDPR Article 6(1):

Where we handle special category data (e.g. health information about a service user), our additional Article 9 condition is your explicit consent or the substantial public interest in safeguarding vulnerable adults (UK GDPR Article 9(2)(g), Data Protection Act 2018 Schedule 1 Part 2).

5. Who we share your data with

We share personal data only with the following recipients, and only for the purposes described:

• Companions who visit you, limited to the information needed to provide visits (name, address, phone, what you've told us about the support needed)
• Stripe for payment processing
• Supabase for database and authentication hosting
• Resend for transactional email delivery
• Twilio for SMS notifications
• Tawk.to for in-platform live chat
• PostHog for product analytics (with your consent)
• Meta (Facebook) for advertising attribution, where you have consented to marketing cookies
• Lovable as our development platform
• CareCheck (eBulkPlus) for DBS checks during companion onboarding
• Murrayfield Solicitors (James Haigh) as our legal and data protection advisor
• Law enforcement, safeguarding authorities, and the Care Quality Commission where a safeguarding referral is required

We will never sell your personal data.

6. International transfers

Most of our service providers are based in the UK or EEA. Where data is transferred outside the UK, we rely on UK Adequacy Regulations (for EEA transfers) or the UK International Data Transfer Agreement (for other transfers). We will take steps to ensure your data continues to be protected.

7. How long we keep your data

We keep personal data only for as long as we need it.

• Account data: for as long as your account is open, plus 6 years to meet our legal and contractual obligations
• Visit notes and safeguarding records: 10 years from the date of the visit (consistent with the Limitation Act 1980 for personal injury claims)
• Marketing data: until you withdraw consent or 3 years of inactivity, whichever is sooner
• Companion vetting records: for the lifetime of the companion's account plus 6 years
• Payment records: 6 years from the transaction (HMRC requirement)

8. Your rights

Under UK data protection law you have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Delete your data, where we have no overriding lawful basis to keep it
• Restrict processing in certain circumstances
• Object to processing, including direct marketing
• Receive your data in a portable form
• Withdraw consent at any time (without affecting prior processing)

To exercise any of these rights, email lucie@aircarers.co.uk. We will respond within one calendar month.

9. Cookies

We use cookies and similar technologies. Our use of cookies is described in our Cookie Policy.

10. Security

We take security seriously. We use encryption in transit (HTTPS), encryption at rest for sensitive data, role-based access controls, and regular access reviews. No system can be guaranteed 100% secure, but we work hard to keep your data safe.

11. Children

This platform is for adults aged 18 and over. We do not knowingly collect personal data from children. If you believe we hold data about someone under 18, please contact us at lucie@aircarers.co.uk.

12. Automated decision-making and AI

We use AI-assisted tools to support some of our operations (for example, to flag patterns in visit notes that may indicate a welfare concern). No automated decision is made about you that produces a legal or similarly significant effect without human review.

13. Changes to this policy

We may update this policy from time to time. The date at the top shows when it was last updated. We will notify you of significant changes by email or via a banner on the platform.

14. How to complain

If you are unhappy with how we have used your data, please contact us first at lucie@aircarers.co.uk. If you remain unhappy, you have the right to complain to the Information Commissioner's Office at ico.org.uk or by calling 0303 123 1113. Quote our registration number [ICO REGISTRATION NUMBER PENDING].

15. Contact

Aircarerscompanion Ltd · Company No. 17175837
Registered office: 57A Commercial Street, Rothwell, Leeds LS26 0QD (c/o FutureProof Accounting)
Operational address: Ware, Hertfordshire
lucie@aircarers.co.uk · aircarerscompanion.co.uk

See also: Cookie Policy · Terms of Use · Safeguarding Policy