neurobox Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1.Introduction
This Privacy Policy is provided by neurobox Limited, a company registered in England and Wales under company number: 10744571 with registered office Suite 4, Bishop Bateman Court, 5-7 New Park Street, Cambridge CB5 8AT (‘we’, ‘our’ or ‘us’) for use of our products and services including our website www.neurobox.co.uk (Website) (Services).
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
2. What Does this Policy Applies to
This privacy policy relates to your use of the Services (including the Website) only.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3. Personal Data We Collect About You
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
| Category of data | How We Collect the Data |
| Identity information when we provide you with Services, including but not limited to when we enter into a contract with you for the Services | Your name, phone number and email address, business name, job title |
| Special category data (health information) when we provide Services to you | In some circumstances we may need to collect health data to provide the Services such as:
We will only collect special category data with your explicit consent. You can read more about how we collect and process this data in the section ‘Sensitive Data’ below. |
| When you participate in an insight panel, respond to a survey or provide feedback | Your name, phone number and email address |
| When you place an order for a product or when we need to deliver a product to you | Your home, business or postal address |
| Credit card and banking data when you make a payment on our Website. | Your full name, address, email address, your credit card details or bank account details |
| Data collected when you use specific functions in the Services. | Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were) |
| Other data the Services collects automatically when you use it. | Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use. Your timezone and/or country |
| Data collected when you make an enquiry with us. | Your name and email address. If you contact us via social media, your social media profile details |
If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4. Sensitive Data
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect information about criminal convictions from individuals and that you should not submit this data to us.
We may, with your consent, collect data concerning health in some limited circumstances when providing the Services, such as when conducting an assessment. This may be collected by us or a third party contractor we engage to conduct the assessment on our behalf (see more details in ‘Who We Share Your Personal Data With’). Please do not submit any other sensitive data to us, unless we have requested it from you.
If, however you do submit unsolicited sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.
5. How Your Personal Data is Collected
We collect personal data from you directly when you sign up to the Services or we perform the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.
6. How and Why We Use Your Personal Data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
| Create and manage your account with us | To perform our contract with you or to take steps at your request before entering into a contract. |
| Providing services and/or the functionalities of the Services to you | To perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) |
| To conduct feedback or insight panels | To better develop our Services and for advancement of research |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances:
in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices | Depending on the circumstances:
in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you |
| Protect the security of systems and data | To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Operational reasons, such as improving efficiency, training, and quality control or to provide support to you | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you |
| Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app |
| Updating and enhancing user records | Depending on the circumstances:
|
Depending on the circumstances:
where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services |
To comply with our legal and regulatory obligations |
| To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances:
in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets |
See ‘Who we share your data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
7. Marketing
We intended to email marketing to inform you of our services such as promotions.
We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
- contacting us at jen@neurobox.co.uk
- using the ‘unsubscribe’ link included in all marketing emails you may received from us
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
8. Who We Share Your Personal Data With
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers, cloud storage providers.
We use the following data processors to handle personal data we collect:
- Amazon Web Service to host our Website and Services
- Hubspot to manage our Website, orders for Services, marketing and customer records and CRM system
- neurohub for management of our records and bookings
- Salesforce
- Xero to manage our invoicing
- Stripe to manage payments via the Website
- Microsoft Outlook for email communication
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
- external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
9. How Long Will My Data Be Kept
We will keep your personal data for as long as you have an active account or contract with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
10. Transferring Your Personal Data Out of the UK?
In some circumstances we do transfer personal data outside of the UK. Where we do, we comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. We currently only transfer personal data outside of the UK to within the EEA (relying on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
11. Your Rights
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
| Access to a copy of your personal data | The right to be provided with a copy of your personal data. |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data. |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations. |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. |
| To object to use | The right to object:
|
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by the Services. |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please complete a request form—available on our website at [insert link] or email , call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
12. Keeping Your Personal Data Secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
13. How to Complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
14. Changes to this Privacy Policy
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.
15. How to Contact Us
Our contact details are shown below:
- Data Protection Officer: Ben Lewis
- Email address: hello@neurobox.co.uk
- Telephone number: 01223 608 491
- Postal address: Suite 4, Bishop Bateman Court, 5-7 New Park Street, Cambridge CB5 8AT