Privacy Policy

01 Who We Are

THURLOW KEMP LTD (trading as OurGrapeVine) operates the OurGrapeVine wellbeing activity service at ourgrapevine.co. We are the "data controller" for the personal information described in this Policy, which means we decide how and why your information is used.

Our registered details are set out in section 10 below.

02 What Information We Collect

2.1 Information You Give Us

When you register, we collect:

• Your name, email address, and phone number;
• Your home address and postcode;
• If you choose to connect a Smart Meter, your MPAN and/or MPRN and energy supplier name;
• Details of anyone you invite to follow your activity (name, email address, and their relationship to you); and
• Any messages you send through the Service, including to your Followers.

2.2 Information We Collect Automatically

Once your Account is active, we collect:

• Daily Check-In button presses — the date and time only;
• If connected, data from your chosen Activity Signal (Smart Meter, smart plug, motion sensor, passage sensor, door sensor, or another device), as described in our Terms & Conditions;
• Basic technical information such as your IP address and browser type, for security and to keep the Service working properly; and
• Records of when you log in, so we can keep your Account secure.

2.3 What We Do Not Collect

We do not collect video, audio, or photographic imagery from any connected sensor. We do not collect health or medical data, and the Service is not a medical device.

03 How We Use Your Information

We use your information to:

• Create and manage your Account;
• Provide the Service, including your activity dashboard and Daily Check-In;
• Learn your typical daily pattern so we can highlight when something looks different from usual;
• Send you and your Followers notifications you have asked for;
• Respond to you if you contact us for support; and
• Meet our legal and regulatory obligations.

We do not use your information for automated decision-making that has a legal or similarly significant effect on you, and we do not sell your information to anyone.

04 Our Legal Basis

Under UK GDPR, we must have a lawful reason to process your information. We rely on:

Full details of the legal basis for each type of processing are set out in our Terms & Conditions.

05 Who We Share Information With

5.1 Followers You Invite

We share an activity summary with any Follower you invite — for example, whether you have had activity today. We do not share your raw Activity Signal data, your address, or your other Account details with a Follower.

5.2 Service Providers

We use a small number of trusted service providers to help us run OurGrapeVine, including:

• Cloud hosting providers, to store your data securely;
• Email providers, to send you sign-in codes and notifications; and
• Where you have connected a Smart Meter, the DCC network and any authorised intermediary required to retrieve your meter data.

These providers only process your information on our instructions and are contractually required to keep it secure.

5.3 Legal Reasons

We may share your information with law enforcement, regulators, or courts if we are legally required to do so.

5.4 International Transfers

We host our data within the UK. If we ever need to transfer data outside the UK, we will only do so with appropriate legal safeguards in place.

06 How Long We Keep Your Information

When a retention period ends, we securely delete or anonymise the information. You can ask us to delete your information earlier — see section 8.

07 Keeping Your Information Secure

We protect your information using encryption in transit and at rest, restricted access controls, and regular security reviews. If we ever become aware of a data breach likely to put your rights at risk, we will notify you and the ICO without undue delay, as required by law.

Please keep your Account password and sign-in codes to yourself, and contact us straight away if you think someone has accessed your Account without permission.

08 Your Rights

Under UK GDPR, you have the right to:

• Access the information we hold about you;
• Correct information that is inaccurate or incomplete;
• Delete your information, where there's no good reason for us to keep it;
• Restrict how we use your information in certain circumstances;
• Receive a copy of your information in a portable format; and
• Object to certain types of processing.

To exercise any of these rights, contact us using the details in section 10. We'll respond within one calendar month, free of charge in most cases.

09 Children

OurGrapeVine is intended for adults aged 18 and over. We do not knowingly collect information from children. If you believe a child has provided us with personal information, please contact us and we will remove it.

10 Contact & Complaints

If you have any questions about this Policy or how we handle your information, please contact us:

If you are unhappy with how we have handled your information, you also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

11 Changes to This Policy

We may update this Policy from time to time. If we make a material change, we will notify you by email before it takes effect. Minor updates, such as corrections, may be made without prior notice — the version number and effective date at the top of this page will always reflect the current version.