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Draft. This notice is still being written and is not yet in force. Parts marked [to be confirmed] are still being decided.

Gabriel privacy notice


Last updated: [to be confirmed]

This notice explains what Gabriel collects, why, who sees it, how long we keep it, and your rights. It is written for four groups of people:

Who we are

Gabriel is provided by Matix Ventures, 71-75 Sheldon Street, Covent Gardens, London, WC2H 9JQ (“we”, “us”). We are the controller of your personal data. You can contact us at support@mygabriel.care.

Gabriel is not an emergency service. We never contact the emergency services. If someone is in danger, call your local emergency service provider.

The short version

What we collect, and why

If you are looked after by Gabriel

WhatExamplesWhy
Your accountYour first name, your email address, your time zoneTo sign you in, to tell your caregivers who an alert is about, and to apply your local times
Your phoneA random id we create for the installation, the phone’s push address, the app and system version, whether notifications and background updates are on, whether it is a phone or a tablet, and when it last contacted usTo send you check-ins, and to tell whether monitoring is working. If your phone stops contacting us, we say we don’t know how you are — we never treat silence as inactivity
Your movement and stepsFrom your phone’s built-in motion record: the kind of movement (walking, running, cycling, or being in a vehicle) and its times; how many steps you took in each hour; the 5-minute periods in which the phone was moved or picked up; when you opened GabrielTo decide whether there are recent signs that you are up and about, and to show your day’s activity
Your settingsWhen your day usually starts and ends, the time we check in each morning, quiet times when you’d rather not be asked, pauses (for example while you are away)So we only check in when it makes sense
Check-ins and help requestsWhen we checked in, whether it reached your phone, your answer (“I’m fine” or “I need help”), when you pressed “I need help”, and when someone said they had been in touchTo make sure an unanswered check-in or a call for help reaches someone
Your routine (only if this feature is switched on for you)Which 15-minute periods of your day are usually quiet, worked out from your movement record; suggested quiet times and your answersTo suggest quiet times you can accept or decline
Who you share withYour caregivers, their role, what each of them can see, and a monthly reminder of who can see your updatesSo you stay in control of who sees what
Your emergency contacts (if Gabriel looks after you)The name, mobile number and relationship (“Daughter”) you give us for each contactTo text them if a check-in goes unanswered or you ask for help

On iOS, Gabriel may also ask to be told by Apple Health when new step data arrives. This only wakes Gabriel up so your updates are current: we never read any Health data, and never share it.

If you are a caregiver

WhatWhy
Your first name and email addressTo sign you in and to show the person who is looking after them
Your phone (as above, without movement)To send you alerts
The alerts you receive and whether you read them; when you said you had been in touchTo run alerts and to keep a history
Changes you make to the person’s settings (for example quiet times, if you are the primary caregiver)So the person is told about the change and can undo it
Your mobile number (if you are the primary caregiver and agree to be texted)To text you as well as alerting you in the app
The name you type when you invite someone, until they joinTo show you who you invited
When you last opened Gabriel (to the minute; only the latest, no history)To show the people you look out for when you were last around (“Last seen”). We keep this only while nobody looks after you

If you are an emergency contact

Somebody using Gabriel gave us your name, your mobile number and how you know them (for example “Neighbour”). We use them only to text you:

  1. once, to ask whether you agree to be their emergency contact;
  2. and, only if you agree, if they don’t answer a check-in for a while or ask for help.

Each text contains their first name, what happened and when, and a link. When you open the link we record your answer (“yes”, “no”, or “I’ve been in touch with them”). The page uses no cookies and no tracking. To protect the page from abuse, we keep a scrambled code derived from your network address for a short time — never the address itself.

If you say no, or follow the “stop” link, we delete your name and number straight away and keep only a scrambled code of the number so nobody can ask you again. If you said no, that code goes after 30 days; if you opted out, it is kept until you ask to receive texts again.

You can ask us about your data at support@mygabriel.care. You have the rights described below.

If you visit our website or join the waitlist

Visiting www.mygabriel.care. Our website sets no cookies and uses no analytics and no tracking. Like any website, it can only reach you by your browser telling it your network address, so two providers see that address when a page loads:

Joining the waitlist. If you leave your email address, we keep:

WhatWhy
Your email addressTo email you when Gabriel is available
Which phone you’re interested in — iPhone or Android — if you chose one of the store buttonsSo we tell you when Gabriel is available for your phone
When you joinedTo know how long we have kept it

That is all: no name, and nothing that links your email address to your network address. We never tell anyone whether an email address is on the waitlist, and we don’t use it for anything else.

To stop automated sign-ups, when you send the form we keep a scrambled code derived from your network address (never the address itself) to limit how many sign-ups come from one connection. It is not linked to your email address, and it is deleted within two hours.

You can leave the waitlist at any time: [to be confirmed] or email support@mygabriel.care. We then delete your email address. [to be confirmed]

What we don’t collect

Special category data

Information about your movement, routine, check-ins and requests for help is collected to judge whether you might need help. It is likely to be information about your health, which the law protects more strongly.

[to be confirmed]

Our lawful bases

[to be confirmed]

PurposeWhose dataOptions for the lawful basis (Art. 6)Note
Running your account and sign-ineveryone with an accountcontract (6(1)(b))
Monitoring and check-ins for the person looked afterperson looked aftercontract (6(1)(b)) or consent (6(1)(a)) — plus the Art. 9 condition aboveConsent is withdrawable at any time; contract fits a service the person signed up for
Telling caregivers (alerts, updates, the activity view)person looked afteras above; the person chooses each caregiver and what they seeThe detailed view is an explicit per-caregiver choice
Caregivers’ own datacaregivercontract (6(1)(b))
Texting emergency contactsemergency contactlegitimate interests (6(1)(f)) for the first text asking whether they agree, then their agreement (consent, 6(1)(a)) for alertsA legitimate-interests assessment is needed for the first text
Keeping records after an event (history, audit trail)person, caregiverlegitimate interests (6(1)(f)) / legal obligation (6(1)(c))Depends on the retention decisions below
Security and abuse prevention (rate limits, logs)everyonelegitimate interests (6(1)(f))
Emailing you when Gabriel is available (the waitlist)waitlistconsent (6(1)(a))You ask by joining, and withdraw by leaving the list
Loading the website’s fonts from Googlewebsite visitorslegitimate interests (6(1)(f))Google receives the visitor’s network address
Improving how Gabriel decides when to check in (check-in outcomes; the routine learner’s comparison records)person looked afterlegitimate interests (6(1)(f)) or consentHealth data: needs an Art. 9 condition too; consider making it opt-in during the beta
The name a caregiver types for someone they invitenamed third partylegitimate interests (6(1)(f))Deleted 30 days after the invitation is used or expires

Who sees your data

The people you choose. Your caregivers see whether there are recent signs of activity, whether your phone is in touch with us, whether you have answered a check-in, whether you have asked for help, any pause, your quiet times, and a simple timeline of your day (for example “movement around 9:15”). They never see your step counts, where you are, or “in a vehicle”. You can let a caregiver see a detailed view that also shows periods of walking, running or cycling; you choose this for each person separately, and can turn it off at any time. Your primary caregiver can change your quiet times; you are told and can undo it. Once a month we remind you who can see your updates.

If you are a caregiver, the people you look out for see when you last opened Gabriel (“Last seen”, to the minute), while they are sharing with you. This is always shown. We don’t record when someone who is looked after opens Gabriel.

Your emergency contacts (if Gabriel looks after you) receive only the texts described above.

Us. A small number of people who run Gabriel can access the data to keep the service working, to investigate problems, and [to be confirmed]. [to be confirmed]

Service providers who process data for us under contract:

ProviderWhat forWhat they receiveWhereTransfer safeguard
RenderHosting our servers and databaseEverything we holdFrankfurt, Germany (EU)EU — UK adequacy regulations. [to be confirmed]
RenderServing our websiteA visitor’s network address and the pages and pictures they loadRender’s worldwide network [to be confirmed][to be confirmed]
Google (Google Fonts)The website’s fontsA visitor’s network address and browser detailsUSA and elsewhere [to be confirmed][to be confirmed]
ResendSending emails [to be confirmed]Your email address and the emailSent from Ireland; account data, including email addresses, stored in the USA[to be confirmed]
TwilioSending texts to emergency contactsThe contact’s mobile number and the textUSA[to be confirmed]
AppleDelivering notifications to iPhonesThe phone’s push address and the notification (for caregivers, the person’s first name and the kind of alert)USA and elsewhere[to be confirmed]
Google (Android only, when Android is released)Delivering notifications to Android phonesAs for Apple[to be confirmed][to be confirmed]

We don’t sell your data. We don’t use it for advertising. We don’t use artificial intelligence to make any decision about you: every decision is made by fixed rules.

We may disclose data if the law requires it. [to be confirmed]

How long we keep it

DataHow long
Detailed movement and step records90 days
Routine picture, quiet-time suggestions log, daily comparisons90 days (decided suggestions: 30 days after)
Change-by-change record of your status90 days
Check-ins, help requests, pauses, caregivers’ alerts[to be confirmed]
Emergency contactsWhile they are your contact. If a contact says no or stops texts, their name and number are deleted at once
The words of texts we sent30 days
Sign-in codes1 day after they expire
Ended sign-in sessions30 days
Invitations30 days after use or expiry
Monthly sharing reminders90 days
Server logs (which never contain email addresses, phone numbers or network addresses)14 days
BackupsUp to 7 days
Waitlist email addresses[to be confirmed]
The scrambled code that limits website sign-upsTwo hours
The audit trail (a record of what the system did and when, using account numbers, not names or email addresses)[to be confirmed]
Everything, after you close your accountErased within 30 days (backups: up to 7 days more)

Your rights

You have the right to:

We answer requests within one month. Emergency contacts, invited people and people on the waitlist, who have no account, can use the email address.

Children

[to be confirmed]

Automated decisions

Gabriel decides automatically when to send a check-in and when to alert caregivers or emergency contacts, using fixed rules about the time since the last sign of activity, your settings and whether your phone is in touch. It never draws a conclusion about how anyone is; it only asks, and tells the people you chose. [to be confirmed]

Security

Data travels encrypted (HTTPS). The database is not reachable from the internet. Sign-in codes, invitation codes and links are stored only in scrambled (hashed) form. Logs are scrubbed of email addresses, phone numbers and network addresses.

Changes to this notice

If we change this notice in a way that affects you, we will tell you in the app [to be confirmed] before the change takes effect.

Contact

support@mygabriel.care · [to be confirmed]