FairPath Privacy Policy — DRAFT for solicitor review

Status: draft. Written to be accurate to the product as designed. Before publication, a solicitor must resolve the open questions below and sign off.

Open questions for review:

1. Article 9 — preparing a Fair Deal application necessarily reveals that the person needs nursing care, which may be health data. We now capture explicit consent (the account owner ticks a box before any of the person's details are entered) and record when it was given. Confirm this is a valid Article 9(2)(a) condition and that the wording is adequate.
2. Confirm the processor list and international-transfer safeguards once wiring is final (currently: EU-region hosting, Resend for email, Stripe for payments — EU regions selected; SCCs where any transfer occurs).

Note: PPS numbers are no longer collected at launch — removed from the product — so the previous PPSN question is resolved by not processing them at all.

Who we are. FairPath is a trading name of Compound Life Ltd, a company registered in Ireland (CRO no. 788749) ("we"). We are the data controller for the personal data described here. Contact: hello@fairpath.ie. We are independent of the HSE.

The short version. We collect only what the Fair Deal application needs, we never sell data, we do not ask for PPS numbers, invited family members see tasks — not financial figures — unless the account owner grants more, and nothing you type into the calculator is saved unless you ask us to email it.

What we collect, and why

The free calculator. The figures you enter are processed in your browser to show the estimate. They are not transmitted or stored unless you choose "email me the breakdown," in which case we keep your email address and the figures you asked us to send. Lawful basis: consent, withdrawable any time via the unsubscribe link in every email.

The Family File (paid). To prepare the application we collect what the HSE's form requires: the applicant's identity and contact details, financial details (income, accounts, assets, deductions), household details, and the details of family members you invite. Lawful basis: performance of our contract with you. Payment is processed by Stripe; we never see or store card numbers.

Sensitive data & consent. Preparing a Fair Deal application necessarily reveals that the person needs nursing care. Before any of their details are entered, the account owner gives explicit consent to us processing that information for this single purpose, and confirms they are entitled to provide it. We record that consent and when it was given. You can withdraw it at any time by asking us to delete the file. We do not collect PPS numbers.

Invited family members. When you invite a sibling or helper, we use their email to send the invitation and operate their access. By default they see tasks and progress — not financial figures. Invitees are never added to any marketing list; only people who subscribe themselves receive marketing.

Usage data. We measure how the product is used (pages, events, timings) to improve it and, in aggregate and anonymised form, to publish statistics such as typical preparation times. Lawful basis: legitimate interests. No advertising trackers.

Cookies

We use a single essential cookie to keep you signed in to the Family File — the portal cannot work without it, so it carries no consent banner. Our usage analytics are cookieless and hold no advertising identifiers. We set no third-party or advertising cookies.

Where it lives and how long

Data is hosted within the EU. Family File data is retained while your account is active and for 12 months after closure, then deleted; email-list data until you unsubscribe; transaction records for the periods Irish tax law requires. You can ask us to delete your account and its data at any time.

Who we share it with

Only the processors needed to run the service — EU-region hosting, Resend (email delivery) and Stripe (payments) — each under a data processing agreement, and nobody else. Where any processing occurs outside the EEA it is covered by Standard Contractual Clauses. We never sell personal data. We share nothing with nursing homes: calculator entries made through a home's embedded widget are never visible to that home. Where a page discloses that we receive a fee from a listed provider, no personal data is shared with that provider unless you contact them yourself.

Your rights

Access, rectification, erasure, restriction, portability, and objection — email hello@fairpath.ie and we will respond within one month. Where we rely on your consent, you can withdraw it at any time. You can complain to the Data Protection Commission (dataprotection.ie) at any time.

The applicant's data, the family's hands

The Family File exists to prepare an application that belongs to the person going into care. Whoever creates the account confirms they are entitled to provide that person's information — typically as the applicant themselves, their nominated helper, or the holder of an appropriate authority (such as a registered EPA).

Last updated: 8 August 2026 (draft). We will notify account holders of material changes.