Privacy Policy

Privacy Policy

v1_0, last updated 23 March 2020

 

IMPORTANT: PLEASE READ THIS PRIVACY POLICY AS IT APPLIES TO ANY PERSONAL DATA YOU PROVIDE US OR WE COLLECT ABOUT YOU, FOR EXAMPLE IF YOU ACCESS THE WEBSITE AT WWW.COMIND.IO OR ANY OTHER WEBSITE OWNED, OPERATED OR PROVIDED BY COMIND TECHNOLOGIES, INCORPORATED IN ENGLAND, COMPANY # 11729526, REGISTERED OFFICE 5-7 MANDEVILLE PLACE, LONDON, W1U 3AY (‘WEBSITE’ AND ‘COMIND’, ‘US’, ‘WE’ RESPECTIVELY) (‘SERVICES’). WE DO NOT MARKET TO OR ENTER INTO CONTRACTS WITH CHILDREN NOR DO WE COLLECT PERSONAL DATA FROM ANY PERSON UNDER 18 YEARS OF AGE.  PLEASE DO NOT ACCESS OR USE THE WEBSITE OR SERVICES IF YOU ARE UNDER 18 YEARS OF AGE.

 

This Policy

 

This policy sets out what personal data we might collect, how we process and protect that data, the lawful grounds for that processing, and your related rights. Essentially ‘personal data’ means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly from that information alone or in conjunction with other information.

 

In most cases, the lawful ground will be that the processing: (i) is necessary for our legitimate interests in carrying out our business, provided those interests are not outweighed by your rights and interests (‘Legitimate Interests’), (ii) is necessary to perform a contract with you (‘Contract’), or (iii) is necessary to comply with our legal obligations (‘Legal Obligation’). Where processing is based on your consent (‘Consent’), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.

 

For the purposes of European data protection law, (the “Data Protection Law“), the data controller is CoMind Technologies of 5-7 Mandeville Place, Lindon, W1U 3aY.

 

As data protection law and practice are constantly developing, we’ll need to update this policy from time to time, which we’ll do by posting a new policy on the Website that takes effect from the date stated.  It is your responsibility to return to the Website from time to time and check for changes.

 

How Do We Collect Personal Data?

 

We collect or are provided personal data in the normal course of business, for example:

  • Information you give us. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register for further information on our site, or when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number.

  • Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:

    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

    • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), information you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.

  • Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

 

When you provide us with personal data about yourself or another person, you are confirming to us that you are authorised to provide us with that information and that any personal data you give us is accurate and up-to-date. 

 

Sensitive Personal Data

 

Given the nature of our business, we do not ask for ‘sensitive’ or ‘special categories of personal data’, such as information about your health, political opinions, racial origins or sexual life and we would ask you not to send any to us.

 

How We Use Your Information

 

We use information held about you in the following ways:

  • Information you give to us. We will use this information:

    • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

    • to provide you with the information about goods or services we feel may interest you, if you have ticked the relevant box situated on the form on which we collect your data indicating your consent to receiving marketing material from us;

    • to notify you about changes to our service;

    • to ensure in our legitimate interests that content from our site is presented in the most effective manner for you and for your computer.

  • Information we collect about you. We will use this information:

    • to administer our site under our terms and for internal operations, including troubleshooting, and, in our legitimate interests, data analysis, testing, research, statistical and survey purposes;

    • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

    • to allow you to participate in interactive features of our service when you choose to do so;

    • as part of our legitimate efforts to keep our site safe and secure;

    • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them in our legitimate interests and subject to your stated preferences where relevant.

  • Information we receive from other sources. We will combine this information, with the information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

 

Sharing Data & International Transfers

 

We will not give, sell or rent your personal data to third parties so they can market their services to you. Nor do we accept advertising from third parties on the Website.  We may share personal data in the following limited circumstances.

  • For provision of the Services, and for our own disaster recovery and business continuity purposes, we may store or transmit personal data to or through third party providers, such as with our contractors and advisors to help us operate, secure and analyse our business. Lawful basis: Legitimate Interests or Contract.

  • We may be obliged to disclose your personal data to comply with a law, order or request of a court, government authority, other competent legal or regulatory authority or any applicable code of practice or guideline. Lawful basis: Legal Obligation.

  • If we enter negotiations with a third party for the sale or purchase of all or part of our business, we will only disclose personal data to that third party to the extent it relates to that business and only under conditions of confidentiality requiring the third party to be bound by the privacy policy that applies to that data. Lawful basis: Legitimate Interests.

 

In each case, we share the minimum personal data necessary and we have written contracts in place incorporating relevant wording to safeguard that personal data and comply with applicable laws, and we will only share such data as is necessary for the purpose in question.  Where possible, we keep personal data within the European Economic Area (‘EEA’).  However, in order to carry out the above purposes, we may use third parties and their facilities outside the EEA.  In all such cases we will ensure that appropriate security measures are in place to protect your personal data and a valid legal basis for the transfer applies.

 

You agree that we have the right to share your personal information with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

  • Selected third parties including:

    • business partners, suppliers and sub-contractors for the performance of any contract we enter into with you; and

    • analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.

 

 

 

Cookies

 

Our Website uses cookies and/or similar technologies.  Please review our Cookie Policy (www.comind.io/cookie-policy) which is part of (and incorporated into) this Privacy Policy for more information, including on how to refuse or selectively accept cookies and/or similar technologies.

 

Retention 

 

As a default position, we will only retain personal data for any statutory retention period, then a reasonable period (if any) necessary for the above purposes.  This is subject, for example, to any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights which is effected.

 

Security

 

The security of data is very important to our business.  In accordance with our legal obligations, we take appropriate technical and organisational measures to protect your personal data and keep those measures under review.  However, we can only be responsible for systems that we control and we would note that the internet itself is not inherently a secure environment.

 

Anonymised Data

 

We may create anonymised data from personal data, and any anonymisation would be carried out in accordance with applicable law as well as relevant guidelines from regulators such as the UK Information Commissioner (‘UK ICO’).  Anonymisation may, for example, be achieved by aggregating data to the point that no individual can be identified such as aggregating website use statistics to see which web content is working well and which could be improved.  Anonymised data does not allow for the identification of any individual person and, as it is no longer personal data, neither data protection laws nor this Privacy Policy would apply to such data.

 

Third Party Services

 

If you access the services of another provider through our websites or services, for example through a link on the Website, your use of those services is entirely at your risk and governed by the terms and privacy policy of that third party provider.  If we resell a service delivered or provided by a third party (‘Third Party Service’), including any software that is delivered or owned by a third party (‘Third Party Software’), it is that third party’s separate privacy policy that will apply to your personal data and your use of the Third Party Service and Third Party Software. Your use of a Third Party Service is not covered by this Privacy Policy. Please therefore review the privacy policy for any Third Party Service and Third Party Software before using it.

 

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.

  • If CoMind Technologies Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of CoMind Technologies Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

 

Where we Store your Personal Data

 

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent Data Protection Law. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Where personal data is transferred we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism which may include by entering into EC approved standard contractual clauses relevant to transfers of personal information (see http://ec.europa.eu/justice/dataprotection/internationaltransfers/transfer/index_en.html ) and that it is treated securely and in accordance with this privacy policy.

 

All information you provide to us is stored on our secure servers.

 

We retain personal data for a period of 5 years for which personal information is stored.  This may include retention necessary to meet to identify issue or resolve legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

Your Rights

 

You have the right to know if we process any personal data about you and, if we are, with certain limitations, to a copy of that personal data. You also have the right to ask us to remove or correct any of that personal data that is inaccurate, to object to certain processing and to withdraw any consent you may have given us for any processing of your personal data. You also have the right to ask us to restrict processing certain of your personal data, to erase your personal data, and to ‘port’ certain of your personal data to you or another provider, provided in each case that we have such data and certain conditions are met.

 

You have the right, at any time, to object to the processing of your personal data for direct marketing.

 

You can also exercise the rights listed above at any time by contacting us at hello@comind.io.

 

‘Do Not Track’

 

The Website does not use technologies that respond to ‘Do-Not-Track’ signals communicated by your internet browser.

 

Contact Us

 

If you’ve any question you can always contact us at the address above or by email to hello@comind.io. You have the right, at all times, to notify a complaint to any regulator such as the UK Information Commissioner, although we would welcome the opportunity to discuss and resolve any complaint with you first.

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The future of non-invasive neural interfaces.

 

To learn more about how we are leading the next cognitive and computing revolution, get in touch with us at: hello@comind.io.