Privacy Policy

This Privacy Policy was last updated on 2/3/2021.

We are committed to protecting and respecting your privacy. This Privacy Policy explains what personal data we collect, how we use it and who you can contact in case of any questions. Please read through this Privacy Policy carefully so that you are fully aware of how and why we are using your data.

The Augmentive Platform which is accessed through the website www.augmentive.io (our “Platform”) is operated and managed by Augmentive Limited (“we”, “us”, “our”). We are registered in England and Wales under company number 12464843 and have our registered office at 25 Ep 25 Eccleston Pl, London, England, SW1W 9NF.

For the purpose of the Data Protection Act 2018, we are the controller of your personal data.

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).

This Privacy Notice applies to you if you are an individual using our Platform for any purpose, including if you are a Professional providing services through our Platform.

We will need to ask you for certain personal information to give you the best possible experience when you access our Platform, receive our services, create a profile on our Platform, or otherwise engage with us (via our Platform, social media channels, email or otherwise).

We do not require you to provide us with any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual origination, political opinions, trade union membership, information about your health, genetic biometric data, and criminal convictions). If you choose to provide us with any special categories of data, you give us your consent to process it and we rely on consent as a legal basis for processing such data.

We use different methods to collect data from and about you including through:

Direction Interactions. We may collect the following personal data from you directly:

• For all users of our Platform and/or services: Any personal data you provide when you (i) get in touch by phone, email, through our Platform, social media channels, or otherwise; (ii) create an account on our Platform (ii) register for and/or use any other services on our Platform including attending an event; or (iii) request marketing to be sent to you. Personal data collected is likely to include your name, email address, telephone number as well as your answers to any online questionnaires or assessment questions that you complete on our Platform.
• For Professionals only: Any personal data you provide when or in connection with creating a profile with us or providing us with content, including your contact information (e.g. name, email address, telephone number), occupation, job details, qualifications, social media handles, personal description and photograph.

Automated technologies or interactions. We will also collect other information about you and the devices you use to access our Platform, or we may ask third parties to do this for us via technologies such as cookies. These are used to distinguish you from other users of our Platform and enhance your experience of using our Platform.

For more information about the cookies we use and the purposes for which we use them please see our Cookie Policy.

Third parties or publicly available sources. We may receive the following information about you from various third parties or publically available sources:

• Where you are accessing our Platform because your employer or other organisation has signed you up or provided you with access then we will provide information about you from that employer or other organisation. That will include your name, email address, telephone number and your job title.
• Your payment details (from our payment processors Stripe, when you make payment for our services or the services of our Professionals.
• Any personal data you provide through our social media channels (e.g. your name and photos in Facebook comments).

We will use your personal data for the following purposes and legal bases:

Performance of a contract

• To provide you with the information and services that you request from us.
• To deal with any enquiries or requests you make of us.
• To enable you to access our Platform and use our services.
• To make recommendations to you about which of our Professionals are likely to be suitable for you.
• To manage our relationship with you.

Our legitimate interests

• To send you important service updates regarding our Platform, our services and our Terms of Use (including this Privacy Policy).
• To confirm your identity and authenticate the information you provide for security purposes.
• For our own reporting and analytical purposes to enable us to improve our services and our user relationships and experiences.
• For our own record-keeping and general administrative purposes regarding our handling of your personal data and other operational activities.
• To provide you with our support and resolve any complaints.
• To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
• To improve our Platform to ensure that content is presented in the most effective manner for you and for your computer.
• To effectively handle any legal claims or regulatory enforcement actions taken against us, or take appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us.
• To assist with our internal training purposes.

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To comply with our legal obligations

• To comply with our legal and regulatory obligations (including under applicable data protection laws).
• For preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
• To fulfil our duties to you, to other users of our Platforms, our Professionals, colleagues and other stakeholders.

Consent

Generally we do not rely on consent as a legal basis for processing your personal data other than (i) in relation to sending third party direct marketing communications to you via email or text message; or (ii) where a feature of our Platform specifically asks you to submit biometric or health data.

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 may disclose your personal data to the following third parties:

• Analytics and search engine providers that assist us in the improvement and optimisation of our Platform.
• Our third party providers of operational and business services, who are authorised to process your personal data on our behalf and pursuant to our instructions as necessary to run our business and provide you with the services you request from us, including our IT, payment and accounting providers.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Any third parties with whom we are required to share your personal data in order to comply with our legal obligations, to enforce our terms and conditions and policies, or to protect the rights, property, or safety of our Platform, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, professional advice and security.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You can request to:

• Access a copy of the personal data we hold about you.
• Rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal data we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal data corrected.
• Delete, restrict or remove the data we hold about you. 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.
• Transfer your personal data that we hold to you or to a third party.
• Object to any further processing of your data, if we are processing your personal data on the basis of our legitimate interests, or for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Withdraw your consent to any processing where consent is a legal basis on which we rely to process your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact Us using the details below.

We will endeavour to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:

• Refuse your request based on the exemptions set out in the applicable data protection laws.
• Request proof of your ID to process the request or request further information.
• Charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests.
• Request more time to respond to you if your request if particularly complex of you have made a number of requests.

If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If we have shared your personal data with others, we will tell them about your request to rectify, erase, restrict or object to the processing where possible.

If you have any concerns about how we handle your data, please Contact Us. If you are not satisfied after we’ve tried to resolve your issue, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO).

Where we need to transfer your personal data to any countries outside the EEA, we ensure that such transfers are made subject to appropriate safeguards as required by applicable data protection laws to ensure that a similar degree of protection is afforded to your personal data, including by ensuring that overseas recipients of your data are located in a country deemed to hold adequacy status or through the use of EU Commission approved standard contractual clauses.

Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Or you can Contact Us at any time using the details below.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we restrict access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.

To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorized use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Your Rights above for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We may need to update this Privacy Policy to reflect changes to our practices, technology and legal requirements. We will post any changes we make to this Privacy Policy on our Platform from time to time and, where appropriate, notify you by e-mail.

All personal data held by us will be governed by the most recent Privacy Policy posted on our Platform, so please regularly check back to see any updates or changes.

This Privacy Policy only addresses our use and disclosure of your personal data.

Our Platform may contain links to other websites, plug-ins and applications, including those of our business partners, our Professionals, and associated social media pages. 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 Platform, we encourage you to read the privacy policy of any external website you visit before you submit any personal data to them.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact us at privacy@augmentive.io.