We are committed to protecting and respecting your privacy. This Privacy Policy explains what personal data we collect, how we use it, who you can contact in relation to questions, how we and you can exercise your Privacy Policy, and how and why we are using your data.

We are committed to protecting and respecting your privacy. This Privacy Policy explains what personal data we collect, how we use it, who you can contact in relation to questions, how we and you can exercise your Privacy Policy, and how and why we are using your data.

The Augmentive Platform (which is accessed through the website www.augmentive.io and our "Platform") is operated and managed by Augmentive, ("we", "us" or "our"). We are registered in England and Wales under company number 10845473 and have our registered office at 35-39 Ladbroke PL London, England, SW11 3HE.

For the purposes of the Data Protection Act 2018, we are the data controller of your 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 Policy 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 experience when you access our Platform, receive our services, create a profile on our Platform, or otherwise engage with us (e.g. via our Platform, social media channels, or interviews).

We do not require you to provide us with any special categories of personal data. 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, 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 for the purposes of providing our services to you.

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

Direct interactions. We may collect the following personal data from you:

• For patients of our Platform: your name, date of birth, personal data you provide to us through your profile, home address, email address, telephone number, and your job title.
• If you create an account on our Platform: your name, date of birth, personal data you provide to us through your profile, home address, email address, telephone number, and your job title.
• For professionals: your name, date of birth, personal data you provide to us through your profile, home address, email address, telephone number, and your job title.
• For all users: your name, date of birth, personal data you provide to us through your profile, home address, email address, telephone number, and your job title.

Automated technologies or interactions. As you interact with our Platform, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

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

• If you are accessing our Platform because your employer or other organisation has approved your use or provides you with services, we will receive personal data from that company or other organisation. This will include your name, email address, telephone number and your job title.
• Your payment details from our payment processor Stripe, when you pay for our services or the services of our Professionals.
• Any personal data you provide through our social media channels (e.g. your profile on Facebook, Instagram, or Twitter).

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 complaints or enquiries you make of us.
• To enable you to access our Platform and use our services.
• To make recommendations to you when a number of our Professionals are suitable for you.
• To manage our relationship with you.

Our legitimate interests

• To send you updates, service updates regarding our Platform, our services, and our Terms of Use (including this Privacy Policy).
• To confirm your identity and authenticate your access to our services and Platform.
• To use data reporting and analytics of our services to enable us to improve and personalise our services and experiences.
• To use your visual branding and general online presence to ensure the marketing of your personal data and other content is accurate.
• To provide you with support and to 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 enforce any legal claims, to recover any money owed to us, or to take appropriate legal action against third parties who have committed an act of fraud or 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 by law).

To comply with our legal obligations

• To comply with our legal and regulatory obligations (including under any 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 as a user of our Platform, our Professionals, our employees and other stakeholders.

Consent

• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message (or where a feature of our Platform specifically asks for your consent to process your 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 may 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, including our IT, security and email service 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 where we are required to share your personal data to comply with our legal obligations, to enforce our Terms and Conditions, 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 inaccurate or incomplete data we hold about you. If it is inaccurate or incomplete, we will amend your personal data we hold about you to be accurate, complete and current. The data we hold about you, however, is not always able to be changed from your personal data removed.
• Erase or remove data we hold about you. 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 a third party.
• Object to any further processing of your data. We are processing your data on the basis of our legitimate interests, or for direct marketing. In some circumstances, we may have compelling legitimate grounds to process your data which override your rights and freedoms.
• Withdraw your consent to any processing where consent is a legal basis for us 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 at privacy@augmentive.io.

We will endeavour to respond to your request within one month of receipt. If we are unable to respond to all of these rights, we reserve the right to:

• Refuse your request, based on the exemptions set out in the applicable data protection laws.
• Process part of your data, or process the request, or request further information.
• Charge you a reasonable administration fee for any requests, remedies or occasions you make.
• Extend the time to respond to you if your request is particularly complex or you have made a number of requests.

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

If you have any concerns about how we handle your data, please Contact Us at privacy@augmentive.io. If we are unable to resolve your issue, you have the right to lodge a complaint with the Information Commissioner's Office (ICO).

Where we store your personal data. We may transfer your personal data to any countries outside the UK or EEA. Where we transfer your personal data to appropriate safeguards are in place to ensure that a similar degree of protection is afforded to it. We will only transfer your personal data by including any transfers to recipients located in a country deemed to hold adequate status or through the use of specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/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 privacy@augmentive.io at any time to make this request.

We have put into 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 limit 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 into 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 is necessary to fulfil the relevant purpose for which we collected your data, including for the purpose of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for holding your 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 data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data: see Your Rights above for further information.

We may revise or update this Privacy Policy to reflect changes to our services, technology and legal requirements. We will post any changes on our website. Please check our Platform from time to time and, where appropriate, we will notify you of any material changes. All personal data held by us will be governed by the most recent Privacy Policy on our Platform, so please regularly check back for 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. 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 every 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.