Owner Agreement

Activity Sharing
Terms & Conditions

Residential & Small Business Owners · Wellbeing Activity Service

Version 2.0 Effective 14 August 2026 Jurisdiction United Kingdom Document Owner Sign-Up Agreement
Please read these Terms carefully before proceeding. By registering for our service and choosing how you would like to share your daily activity, you confirm that you have read, understood, and agree to be bound by these Terms and Conditions. If you do not agree, do not proceed with registration. These Terms form a legally binding contract between you (the account holder, referred to as "you" or "the Owner") and THURLOW KEMP LTD (referred to as "we", "us" or "the Service Provider").

01 Definitions

In these Terms and Conditions, the following words have the following meanings:

TermMeaning
Activity SignalAny data source you choose to connect that indicates activity in your home, including a Smart Meter, smart plug, motion sensor, passage sensor, door sensor, Daily Check-In, or another device you tell us about.
Daily Check-InA manual button press within your Account dashboard that you use to indicate you are safe and well. Available to every Owner at no additional cost, regardless of any other Activity Signal connected.
Smart MeterA SMETS2 (or SMETS1) electricity and/or gas meter installed at your property and connected to the national smart metering infrastructure (DCC), where you have chosen this as an Activity Signal.
Device DataReadings, events, or interval data collected from any Activity Signal you have connected to the Service, including but not limited to consumption data, motion events, door events, and check-in timestamps.
ServiceThe activity monitoring platform, dashboard, analytics tools, and related services provided by us at ourgrapevine.co.
AccountYour registered user account created during sign-up.
FollowerA family member, friend, carer, or other person you have explicitly invited to view a summary of your activity through the Service.
Personal DataAny information relating to an identified or identifiable natural person, as defined under UK GDPR.
UK GDPRThe UK General Data Protection Regulation, as incorporated into UK law by the Data Protection Act 2018.
ICOThe Information Commissioner's Office, the UK's independent data protection authority.
DCCThe Data Communications Company, which manages the national smart metering network in Great Britain. This only applies where you have connected a Smart Meter as your Activity Signal.

02 Eligibility & Registration

2.1 Who May Register

To register as an Owner, you must:

Every Owner has access to Daily Check-In from the moment they register, at no additional cost. If you also choose to connect a Smart Meter as an additional Activity Signal, you must in addition:

2.2 Account Accuracy

You agree to provide accurate, current, and complete information during registration and to keep your Account details up to date. We reserve the right to suspend or terminate Accounts where information is found to be inaccurate or misleading.

2.3 One Account Per Property

Only one Account may be associated with each property address and each connected Activity Signal. If multiple occupiers or owners exist, the Account holder must have authority to consent on behalf of all occupiers for the purposes of data sharing.

2.4 Authorisation to Access Device Data

Where you choose to connect an Activity Signal beyond Daily Check-In, you confirm that you have the legal authority to grant us access to Device Data from that signal at the registered property. Where you are a landlord granting access in respect of a tenanted property, you confirm that you have obtained all necessary consents from your tenant(s) and that your doing so is lawful.

03 Data You Are Sharing

3.1 Daily Check-In Data

Every Account includes Daily Check-In. When you press the check-in button, we record the date and time of the press. This is available to you from the moment you register, with no equipment or connection required.

3.2 Optional Activity Signal Data

If you choose to connect an additional Activity Signal, the categories of Device Data collected depend on the signal type:

Activity SignalData CollectedFrequency
Daily Check-InTimestamp of each button pressAs pressed
Smart meterElectricity and/or gas consumption (kWh), tariff and meter status informationHalf-hourly
Smart plugPower draw of the connected appliance (kWh)Half-hourly
Motion sensorPresence detected in a room (event only, no imagery)As triggered
Passage sensorMovement past a fixed point such as a corridor or doorway (event only)As triggered
Door sensorDoor opened or closed (event only)As triggered
Other / custom deviceAs agreed with you individually before connectionAs agreed

We do not collect video, audio, or imagery from any sensor. Motion, passage, and door sensors used by the Service report activity events only.

3.3 Registration & Account Data

In addition to Activity Signal data, we also process:

3.4 What Followers Can See

Followers you invite can see a summary of your activity pattern — for example whether you have had activity today, and any change from your usual pattern. Followers cannot see the underlying raw data (such as exact energy readings) unless you choose to share more detail through the Service.

04 How We Use Your Data

4.1 Primary Uses

We use your Activity Signal data and Personal Data to:

4.2 Analytical & Service Improvement Uses

With your separate consent (where required), we may also use aggregated or pseudonymised data to:

4.3 Sharing With Followers

Where you invite a Follower to your Account, we will share with that Follower only the activity summary described in clause 3.4. We will not share your full Device Data, Personal Data, or Account details with a Follower without your separate consent.

4.4 What We Will Not Do

We will never:

05 Legal Basis for Processing

We process your data under the following lawful bases as defined by UK GDPR Article 6:

Processing ActivityLawful Basis
Providing the activity monitoring Service, including Daily Check-InPerformance of a contract (Art. 6(1)(b))
Account management and communicationsPerformance of a contract (Art. 6(1)(b))
Sharing Device Data from an optional Activity Signal (e.g. Smart Meter, sensor)Explicit consent (Art. 6(1)(a))
Sharing your activity summary with an invited FollowerExplicit consent (Art. 6(1)(a))
Service improvement and analyticsLegitimate interests (Art. 6(1)(f))
Legal & regulatory complianceLegal obligation (Art. 6(1)(c))
Marketing communicationsConsent (Art. 6(1)(a)) — obtained separately

Where we rely on legitimate interests, we have conducted a legitimate interests assessment (LIA) to ensure our interests are not overridden by your rights and freedoms. A summary of our LIA is available on request.

06 Data Retention

We retain your data for the following periods:

Data CategoryRetention Period
Daily Check-In timestamps24 months from date of collection
Half-hourly Activity Signal data (Smart Meter, smart plug)24 months from date of collection
Sensor event data (motion, passage, door)24 months from date of collection
Daily / monthly aggregated data7 years (for financial and audit purposes)
Account and registration dataDuration of Account + 6 years after closure
Support communications3 years from last interaction
Anonymised / aggregated analyticsIndefinitely (cannot be linked back to you)

On expiry of the relevant retention period, data will be securely deleted or anonymised in accordance with our Data Retention Policy. You may request early deletion of your Personal Data, subject to clause 8 and any overriding legal obligations.

07 Third-Party Sharing

7.1 Sub-Processors

We may engage trusted third-party service providers (sub-processors) to assist in delivering the Service, including cloud hosting, data analytics, and customer communications providers. All sub-processors are contractually bound to process your data only on our instructions and in compliance with UK GDPR.

7.2 DCC & Data Access Services (Smart Meter Only)

Where you have chosen to connect a Smart Meter as your Activity Signal, your Device Data is retrieved via the DCC network using our status as an authorised DCC User or through a registered Third-Party Intermediary (TPI). By consenting to Smart Meter data sharing, you authorise us to make the necessary data access requests to retrieve your Device Data from the DCC on your behalf. This clause does not apply if you use Daily Check-In or another non-Smart-Meter Activity Signal.

7.3 Legal Disclosure

We may disclose your data to law enforcement, regulatory authorities (including Ofgem or the ICO), or courts where we are legally obliged to do so. We will notify you of any such disclosure where permitted by law.

7.4 International Transfers

We will not transfer your Personal Data outside the UK unless appropriate safeguards are in place (such as UK adequacy decisions or International Data Transfer Agreements under UK GDPR Article 46). Our primary data infrastructure is hosted within the UK.

08 Your Rights

Under UK GDPR, you have the following rights in relation to your Personal Data:

To exercise any of these rights, please contact us at support@ourgrapevine.co. We will respond within one calendar month of receiving your request. There is no charge for exercising your rights unless a request is manifestly unfounded or excessive.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

09 Withdrawing Consent & Closing Your Account

9.1 How to Withdraw

You may withdraw consent or close your Account at any time by:

9.2 Effect on Service Access

Withdrawing consent for an optional Activity Signal will mean you can no longer access the features associated with that signal, but Daily Check-In will remain fully available. We will notify you of any specific functionality that will be affected before your withdrawal takes effect. You may still access historical reports for any data period where consent was valid.

9.3 DCC Opt-Out (Smart Meter Only)

If you have connected a Smart Meter, you may independently manage your DCC data access preferences through your energy supplier or the national smart metering opt-out process. Exercising your DCC opt-out will automatically prevent us from accessing future Smart Meter data, but will not affect Daily Check-In or any other Activity Signal.

10 Security

We take the security of your data seriously and implement appropriate technical and organisational measures, including:

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and no later than 72 hours after becoming aware, as required by UK GDPR Article 33.

You are responsible for maintaining the security of your Account credentials. Please notify us immediately at support@ourgrapevine.co if you suspect any unauthorised access to your Account.

11 Liability

11.1 Our Liability

Nothing in these Terms excludes or limits our liability for death or personal injury caused by our negligence, fraud or fraudulent misrepresentation, or any liability that cannot be excluded by law.

Subject to the above, our total aggregate liability to you arising under or in connection with these Terms shall not exceed £500 or the total fees paid by you for the Service in the 12 months preceding the event giving rise to the claim, whichever is higher.

11.2 Service Accuracy

The activity data and insights provided by the Service are for informational purposes only, and do not constitute medical advice, a medical device, or an emergency alerting service. We do not warrant that Device Data readings are error-free or that analytics outputs will be accurate in all circumstances. You should not rely solely on the Service for decisions involving safety, medical, financial, or legal consequences. If you or someone you support is in immediate danger, contact the emergency services directly.

11.3 Third-Party Infrastructure

We are not liable for delays or failures in Device Data availability caused by faults in the DCC network, your energy supplier's systems, connected sensor hardware, or your home internet connection. We will use reasonable endeavours to minimise disruption and communicate service issues promptly.

12 Changes to These Terms

We may update these Terms from time to time to reflect changes in the law, regulatory requirements, or our service offering. When we make material changes, we will:

If you do not agree to the updated Terms, you must stop using the Service and close your Account before the effective date of the changes. Your continued use of the Service after that date constitutes acceptance of the revised Terms.

For non-material changes (such as corrections of typographical errors or clarifications that do not affect your rights), we may update the Terms without prior notice and will update the version number and effective date accordingly.

13 Governing Law & Disputes

These Terms and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales.

In the event of a dispute, we encourage you to contact us in the first instance so that we can seek to resolve the matter informally. If we are unable to resolve a dispute within 30 days of your written complaint, you may refer the matter to an independent Alternative Dispute Resolution (ADR) scheme, details of which will be provided upon request.

Subject to the above, the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim.

14 Contact Us

For any questions about these Terms or our data practices, please contact us:

Company nameTHURLOW KEMP LTD
Registered address[REGISTERED ADDRESS], United Kingdom
Company number03767009
ICO registration numberZ7469706
Contactsupport@ourgrapevine.co