Privacy Policy

Introduction

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Controller

NeuroGEARS Ltd (“we”, “us” or “our” in this privacy policy) is the data controller and is responsible for certain personal data about you that we collect and use to provide the organisation you represent (our “Clients”) with our services (the “Services”) in accordance with our terms and conditions, or where you use or browse our website.

Contact us

If you have any questions about this policy or about how we handle your data, please contact our data privacy team as follows:

Email: privacy@neurogears.org

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We keep our privacy policy under regular review. This version was last updated in September 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Representatives of our Clients

Identity Data: includes name and job title or position within the organisation such as ‘student’ or ‘researcher’.
Contact Data: includes organisation address, email address, telephone numbers, organisation details, and online presence where applicable.
Profile Data: includes your interests, preferences, feedback, your attendance at events and conferences, and orders made by you on behalf of your organisation.
Usage Data: includes information about how you use our website and our Services.

Website users

Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
Usage Data: information about how you use our website, IT, communication and other systems.

We collect and use this personal data for the purposes described in the section ‘how and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing our Services to you or your organisation.

We also collect, use and share aggregate data such as statistical or demographic data for any purpose. Aggregate data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregate data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any “Special Categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.

How your personal data is collected

We collect personal data that you provide directly to us (for example in connection with an inquiry or placing a purchase order) in person, by telephone, email and/or via our website.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a lawful basis, e.g.:

for our legitimate interests or those of a third party;
in certain cases where you have given consent; or
to comply with our legal and regulatory obligations.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.

The table below explains how and why we use your personal data.

What we use your personal data for	Lawful basis	Type of data
To register your organisation as a new Client	Necessary for our legitimate interests (to operate our business)	Identity Contact Profile
To process your organisation’s order as a Client and deliver our Services (which may include your attendance at one of our training or conference events)	Necessary for our legitimate interests (operate our business)	Identity Contact Profile
To manage our relationship with you and with your organisation and to develop, enhance and improve our business	Necessary for our legitimate interests (to keep our records updated and to study how Clients use our Services)	Identity Contact Profile
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (c) Consent	Identity Contact Technical
To deliver relevant website content to your organisation and to carry out marketing to your organisation and to make recommendations about goods or services that may be of interest to your organisation	For our legitimate interest, i.e. to develop and grow our business	Identity Contact Usage
To use data analytics to improve our website, Services, marketing, Client relationships and experiences	Necessary for our legitimate interests (to define types of Clients for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)	Technical Usage
Preventing and detecting fraud against you or us	(a) For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us (b) To comply with our legal and regulatory obligations	Identity Contact
To enforce legal rights or defend or undertake legal proceedings, or to provide information required relating to audits, enquiries or investigations by regulatory bodies.	(a) To comply with our legal and regulatory obligations (b) For our legitimate interests, i.e. to protect our business, interests and rights	Identity Contact Profile
Operational reasons, such as improving efficiency, training quality control and security of our website.	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price	Identity Contact Technical Usage
Statistical analysis to help us manage our business	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price	Technical Usage

Marketing

We will not use your personal data to send you marketing communications and updates about our Services.

We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We routinely share personal data with:

third parties we use to help deliver our Services, e.g. payment service providers or venue hosts and volunteers;
other third parties we use to help us run our business, e.g. website hosts and IT and systems administrators, or other professional consultants that we engage to support us on specific projects;
our bank.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) 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. The recipient of any of your personal data will be bound by confidentiality obligations.

How long your personal data will be kept

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Please contact us at privacy@neurogears.org if you want further information about how long we will retain your personal data.

Transferring your personal data out of the UK

Generally speaking, we will not transfer your personal data outside of the UK.

However, in exceptional circumstances for example if we deal with an international supplier it may be necessary to transfer your personal data to countries outside of the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights please contact privacy@neurogears.org.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Policy last updated: Sept 2024

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