Privacy Policy

Who we are

TIWANI Ltd (TIWANI, we, us, our) runs the website at tiwanilife.com and is building the TIWANI app. For the personal data described here, we are the data controller: we decide what is collected and why. You can reach us at hello@tiwanilife.com.

We are completing our registration with the UK Information Commissioner (the ICO) and our wider data-protection preparation, including the appointment of a data-protection contact, before we collect personal data at scale. We will name a Data Protection Officer here if we are required to appoint one, or if we choose to.

What this policy covers

Today this policy covers the website and the waitlist. The TIWANI app is still being built. When the app opens, it will have its own privacy notice shown at sign-up, covering the data a Coordinator enters to plan care. This page will be updated to cover both.

The information we collect

When you join the waitlist, we collect:

• Your email address, so we can contact you about TIWANI.
• Your care context: the options you tick about who you coordinate care for (for example a child or young person with additional needs, an older adult, someone with a long-term condition, or a professional role). This helps us understand who we are building for.

If you give your consent, we also collect basic, privacy-respecting analytics about how the site is used (see our Cookie Policy). If you do not consent, no analytics cookies are set.

We do not collect health data

TIWANI is non-clinical infrastructure. We do not ask for, and the waitlist does not collect, any health, medical, or diagnosis information, and no special-category data under Article 9 of the UK GDPR. In the app, the planning data a Coordinator enters is held as structured codes, scores, and timestamps; free text is never read by our scoring engine. We design to avoid collecting health data, and we keep what we collect to the minimum we need (data minimisation).

Why we use your data, and our lawful basis

We use your waitlist details to keep you informed about TIWANI, to understand the audience we serve, and to invite you to help shape the product. Our lawful basis for the waitlist is your consent, which you give when you join. You can withdraw it at any time (see Your rights). For the app, we expect to rely on a contract with you and on our legitimate interests in running the service; the app privacy notice will state this exactly.

Who we share it with

We do not sell your data. We share it only with the service providers (processors) that help us run TIWANI, under contract and on our instructions:

• Supabase hosts the database that stores waitlist sign-ups.
• SheetMonkey and Google Sheets hold a working copy of sign-ups for our own planning.
• Google / Firebase Analytics measures site usage, only if you have consented to analytics cookies.
• Firebase Hosting serves the website.

Some of these providers may process data outside the UK. Where they do, we rely on the appropriate UK transfer safeguards (such as a UK adequacy decision or the UK International Data Transfer Agreement). We are confirming the hosting region and the specific safeguard for each provider as part of our launch preparation, and before we collect data at scale we will name the safeguard here and provide a copy of it on request from hello@tiwanilife.com.

How long we keep it

We keep your waitlist details until TIWANI launches and you have had the chance to create an account, or until you ask us to remove you, whichever comes first. If you unsubscribe or ask us to delete your data, we will do so promptly.

Children, and the people you care for

TIWANI is used by adults (Coordinators), not by children. The app will hold planning information about the person someone cares for, which in the first release is often a child. We treat that data with extra care: we follow the principle that the best interests of the child come first, we keep data to a minimum, and we apply the standards expected by the UK Information Commissioner for data about children. Whether and how the ICO Children's Code (the Age Appropriate Design Code) applies to a service used by adults but holding data about children is a question we are taking to qualified advisers before the app collects real data.

Keeping your data safe

Your waitlist details are not readable from the public website: the sign-up list can be added to, but it cannot be read back by the site. In the app, access to data is restricted to the account it belongs to, enforced both in our application and at the database, so one account can never see another account's data. We use reputable, security-reviewed infrastructure and keep the data we hold to a minimum.

Our data protection impact assessment

Because TIWANI will process data about vulnerable people, we will complete a Data Protection Impact Assessment (DPIA), and act on it, before the app processes real family data. The DPIA looks hard at the risks and how we reduce them. This is part of our launch preparation, not an afterthought.

Your rights

Under UK data protection law you have the right to:

• ask for a copy of the personal data we hold about you;
• ask us to correct data that is wrong or incomplete;
• ask us to delete your data;
• ask us to restrict or stop using your data, or object to our using it;
• ask us to move your data to another service (portability);
• withdraw your consent at any time, including for analytics and for waitlist emails.

To use any of these rights, email hello@tiwanilife.com. You also have the right to complain to the ICO at ico.org.uk/make-a-complaint, though we would welcome the chance to put things right first.

Changes to this policy

We will update this policy as TIWANI grows, in particular when the app launches. We will change the date at the top and, for significant changes, let waitlist members know.

Contact us

For anything about your data or this policy, email hello@tiwanilife.com.