Welcome to Braintrain2020 Limited’s privacy policy.

 

Braintrain2020 Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and any mobile application we make available, together being the (“System”), tell you about your privacy rights and how the law protects you.

 

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

 

 

 

 

 

 

This privacy policy aims to give you information on how Braintrain2020 Limited collects and processes your personal data through your use of the System.

 

This System is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

 

Braintrain2020 Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

 

 

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

 

Full name of legal entity: Braintrain2020 Limited

 

Email address: info@sleepcogni.com

 

Postal address: Kroto Innovation Centre, North Campus, University of Sheffield, 318 Broad Lane, Sheffield, South Yorkshire, England, S3 7H

 

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 (www.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 on 18/11/2022.

 

It may change and if it does, these changes will be posted on our website and, where appropriate, notified to you when you next use the System. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the System.

 

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.

 

 

The System 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 System, we encourage you to read the privacy policy of every website you visit. Please check these policies before you submit any personal data to these websites or use these services.

 

 

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:

 

• Identity and Contact Data including your name, email address, phone number, age, date of birth, and gender. You may also be presented the opportunity to provide us with information such as race and ethnicity – this data is not required to be provided to use the System.
• Health and Environmental Data includes formation about your sleep patterns, pre-existing medical conditions and general information about your physical and mental wellbeing. This may also include heart rate, heart rate variability, blood oxygen, movement during sleep, body temperature, galvanic skin response, sleep duration, light levels, humidity, air quality and sound levels.
• Technical Data including formation about the devices you use to access the System, including (but not limited to) internet protocol (IP) address, mobile device identifiers, operating system, and browser type.
• Profile and Usage Data including your username and password, feedback, survey responses and how you use our System, products and services
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated 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. However, if we combine or connect Aggregated 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 information about criminal convictions and offences.

 

 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

 

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

 

• Information you give us. You may give us your Identity and Contact Data Health Data and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Profile and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see details of our use of cookies in section 4 below.

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

We may use the data you provide to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

 

 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

 

We may use personal data about you in creating aggregated data sets shared with our research partners. Once aggregated, the information no longer constitutes personal data, and such aggregated data would be used for supporting generalised statements (for example: “men under the age of 30 have the worst sleeping habits in the UK”).

 

 

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

 

 

We may store cookies (small text files managed by your web browser) on your computer in order to improve your experience with the System. Example uses of these cookies include recognising you when you return to the System, maintaining data you’ve entered across multiple sessions, and storing information about your personal preferences.

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the System may become inaccessible or not function properly.

 

Our software may automatically generate a confirmation when you open an email from us, or click on a link in an email, if your computer supports this type of software. When you receive an email from us, you can opt out of receiving further emails by following the included instructions to unsubscribe. However, by opting out of further email communications after you sign up, you may limit program reminders and other valuable program content and components.

 

 

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 share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

 

• Internal Third Parties being other companies in our group who provided IT and system administration services and undertake leadership reporting.
• External third parties being: service providers acting as processors who provide IT and system administration services, professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances
• 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.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

 

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

 

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.
• 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.

 

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

 

 

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 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 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 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.

 

By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for tax purposes.

 

In some circumstances you can ask us to delete your data: see below 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.

 

 

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

 

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 products or 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 the rights set out above, please contact us.

 

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.

 

 

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.

 

 

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.