We have carried out a data privacy impact assessment for this product in line with ICO recommendations. We are registered with ICO and have a strong commitment to data protection throughout our organisation. All staff complete annual refreshers on data privacy best practice, we consider data use at the beginning and throughout of any development work, and we welcome conversations with our users about their data and experience with our service.
You are the data owner. We (Howz - ; Unit 45 Greenheys Business Centre, Pencroft Way, Manchester, M15 6JJ) are data controllers which means we decide how your information is processed, but we require your permission to collect and use your data.
We consider information in 3 parts personal, pseudonymised and anonymised. Personal information means details that can identify you eg name, address, phone number, pseudonymised means a label is used to name your data which does not identify you but we can link to your identity, and anonymised means any personal identifying information is removed from the data entirely including any links.
Our legal basis for collecting and working with this information is:
To allow us to provide the Howz service and ensure you receive information for the correct site
To allow us to offer support services via our telephone and online contacts
To enable you to share your information with others as you wish
The processing is lawful as it meets the following criteria:
a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
If we change the purpose for which we collect your data and/or process your data we will carry out additional consent procedures.
Information we collect from you about you
You may be registered with Howz directly as the customer for monitoring in your house or as an Important Person.
To register with the Howz system you are required to give us your email address as a user ID and a password, and the town nearest to the installed site. Howz has the right to email you directly with any service issues, changes to the system, changes detected in your data, and data summary reports in order to deliver your service.
To set up your Howz site you are required to enter your name, address, and postcode. In order to continue access beyond your free period you are required to enter your payment details.
Once your sensors are paired with your account we will process the information as part of service delivery. We use automated decision making to describe your daily routine and set alerts accordingly. This information is processed in a pseudonymised format. This information varies according your home set up as follows:
Smartmeter - electricity usage for the house
Motion sensor - movements past the sensor, temperature and light
Door sensor - door opening and closing, temperature
Smart plug - electricity usage on the individual socket
The information you collect is your responsibility and Intelesant has no responsibility for or control over the access to the content, information or data that you generate through use of Howz.
If you want to review or amend any data we store please contact us via and we can discuss your requirements. This may include providing you with a copy of the personal data stored about you, rectifying any details, restricting access to any specific details, or objecting to processing of personal data. If restricting processing of personal information we will discuss the impact of this on your service experience to enable you to make an informed decision about the processing we carry out. You can access your data at any time from a range of devices. You have the right to data portability. On request we can provide a copy of your personal data in a machine readable form.
If you contact us we may keep a record of that correspondence.
Information we collect about you and your device
Every time you use Howz we may automatically collect information about:
the type of mobile device you use;
a unique device identifier and session token;
mobile network information;
your mobile operating system;
whether wifi or mobile data is being used;
your IP address;
the pages you access;
the app version you are using;
time zone setting.
We collect this data using Segment, Google Firebase and Google Analytics. We use this information to analyse app usage, improve performance and provide support to our users. The support function does require an identifier to be used for app usage.
The Howz service offers alerts as push notifications. In order to do this the app requests access to alerts and notifications within your phone settings. You can choose not to allow this at app set up. This will not affect your use of the app but will stop you receiving alerts from us via push notification, they will still appear within the app itself.
The Howz app when used for set up of a Howz Smart Home Kit will request use of the camera. This is to enable you to scan the barcode on the kit. You can decline permission and manually enter the code or you can set up your kit and then turn off the camera permissions in your phone settings.
We do not use any other trackers on your device and so no other permissions are required.
Who sees your information
The customer service team and clinical leads at Howz will see the information that identifies you to enable us to offer customer support. The Howz technical team will see the data from the sensors, but this does not enable them to see the personal information connected to the data and allows them to work on the system ensuring the data is managed effectively.
The customer service and accounts team will access your personal information to establish and maintain Direct Debits for ongoing Howz services.
Where trials are in place, data collected will be shared with the trial partner using anonymisation or pseudonymisation wherever possible. An additional fair processing notice and/or information sheet will be provided for each trial.
The addition of people to view your account is under your control, we call them VIPs as your information should only be shared with people you trust and who understand why you are sharing your information with them. You are responsible for correctly entering their email address and for checking this is correct before you share your data with them. You can withdraw permission for them to see your data at anytime via
How we store your data
All personal information you provide to us is stored on our secure servers. We only share your information through a secure transmission system within the internet. The data transmitted from the monitors in your home contains no personal identifiable information, is stored in the UK or EEA and is encrypted.
A pseudonym is created to enable us to identify your data within our analytics system. This method ensures your data is seen only by those you authorise and that you do not see other people’s information.
Your name, email address, contact phone number (and address if you supply this in communication via customer service) are stored within a system called Zendesk which is fully encrypted (stored in EEA or US under security shield) and only accessible to those who deal with customer service.
Your personal information from the purchase (see howz.com for further details) is stored on an encrypted server provided by Shopify (stored in EEA or US under security shield) and this is only accessible by customer service staff within Howz. The link between your site and your personal information is stored on our secure server in a fully encrypted database.
Your name and address and payment details are stored within Chargebee who are fully compliant with GDPR and PCI.
Your email address is stored within customer.io to enable the dispatch of emails regarding the service or changes within your site. The data is encrypted and stored in compliance with GDPR.
Whilst Howz is open, data is stored on your device. If you backup your device to a service such as the Apple iCloud it is possible that your data might be stored in this service. It is not necessary to back up Howz in this way as all of the information is stored on our own secure servers.
How we use your information for our own purposes and service delivery
We use all information from attached sensors to provide a narrative of daily routine (list sensor activations) and to describe daily routine for a household. Automated decision making is used in the form of machine learning techniques to describe your daily routine from the data collected. The outcomes of this analysis is used to set your alerts detecting changes in your routine. You can view these outcomes via the app and you can change them as you see fit.
We may use the information you share in Howz to continuously improve and develop our products such as new features, better performance and security. We may also use the information to promote the service, evaluate the impact of the service, and share learning through publications. However, information used for these purposes will have all of your personal details removed, and no-one will be able to identify you from the information they see.
We will not sell or otherwise provide any information that identifies you personally to any third party without your permission or without giving you notice about it in this policy.
Usernames and email addresses
Usernames and email addresses are used to uniquely identify you in Howz.
Your username must be your contact email. This is so that we have a way of contacting you or to help you reset your password if you have forgotten it. Please keep your username and password safe.
Your account can be linked to someone else’s email. This may be the case if you do not have or do not want to have an email address and another person is helping you so that you can use Howz. In this case you must be sure that you can trust that other person with your information.
You can choose to link your username to another email address at any time. Contact us if you wish to make a change.
Making changes and deactivating or deleting your account
You may contact us at any time to make changes to your account. You will need your registered site administration email address to confirm identity if you call us. We may ask for further details including the date of purchase or your site identifier before processing your request.
You may withdraw consent, deactivate or delete your account (your ‘right to be forgotten’) or remove messages from your Timeline by contacting Howz customer service via the app or via telephone 0161 226 5353.
You can remove a Very Important Person at any time.
Whilst your account is deactivated you will not be able to record new entries into the app and you will not be able to open the app again. Your Important People will not be able to see any new information or record new messages.
If you change your mind whilst your account is de-activated full use of the app can be restored to you by contacting Howz customer service as above.
If you request that your account is deleted your account will first be de-activated for 30 days. Once your account is deleted you will not be able to restore it. Account deletion means that all personal identifiable information will be deleted from our systems apart from financial records which are required by law to be retained for 10 years. The pseudonym will also be deleted meaning the data from your site can no longer be attributed to you and will become an anonymised dataset. This dataset will be preserved as it is used for machine learning purposes and will be incorporated into existing statistical calculations and system wide processes.
An archive of information stored within the app will be retained by us in accordance with our retention policy (10 years).
What are cookies?
Cookies are small text files that are stored on your device. This helps Us to improve Our service to You.
If you wish to restrict or block cookies you can do this through your browser settings. The "Help" function within your device should give details of how to do this. Alternatively, you can find more details on how to control or delete cookies at
Please note that you may not be able to use many of the services on Our Website or Apps or other websites without cookies.
Types of cookies We use
We currently use:
strictly necessary cookies (cookies that are required for the operation - customer service support (including information about how you use the app and the device you are using, security and navigation of the site);
analytical/performance cookies (cookies that allow us to see how the app is used, address performance issues, and how and when the app is accessed);
functionality cookies (cookies used to recognise you when you return to our App, enabling us to personalise our content for you).
We have a full range of policies relating to data security, these documents can be shared on request. If you have questions or complaints regarding our use of your information and your privacy please contact us by email at or by phone 0161 226 5353 or by post:
Unit 45 Greenheys Business Centre
If you are not satisfied with our response you may contact the Information Commissioners Office with your concerns or a complaint. Please use this link
The following consents are essential to enable the Howz system to work effectively:
I consent to Howz storing and using personal information provided by me to receive Howz sensors and/or set up my Howz service
I consent to Howz contacting me to facilitate the set up of the Howz system and service
I consent to Howz transferring and storing the data from my sensors and gateway using a pseudonym
I consent to Howz retaining my anonymised data post account and pseudonym deletion
I consent to Howz contacting me regarding my Howz service and changes
I understand I may withdraw consent at anytime by contacting Howz directly and any processing of data will be stopped immediately
I understand that I am responsible for the invitation to share the information within the system including who it is shared with, ensuring the email is entered correctly, and they understand the nature of the information shared