Compliance

Brain Powered Ltd of 71-75 Shelton St, West End, London, WC2H 9JQ, UK (we our and us) are committed to the highest standards of privacy and data protection compliance. We are bound by the Data Protection Act 2018 of the United Kingdom (DPA) and the regulations enacted under it (as may be amended from time to time). If you are a resident of the European Union, you are protected by and enjoy additional rights under the European Union’s General Data Protection Regulation 2016/679 (GDPR). We act in accordance with the DPA and this Privacy Policy. If you are a resident of the European Union, you will be able to exercise your rights under the GDPR.

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This Privacy Policy sets out how and why we collect, store, use, transfer and disclose your personal information and how you may access your personal information and correct it. This Privacy Policy also explains the use of cookies on our website www.brainpoweredcoaching.com (our site).

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For the purposes of the DPA and the GPDR the relevant legal entity is Brain Powered Ltd and our nominated Data Protection Officer is Caroline Brewin who can be reached at [email protected] (please include “Personal Data” in the email subject).

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Information we collect, and how we do it

We collect information, both general and personal, in a number of ways, as detailed in this Privacy Policy. In the case of personal or personally-identifiable information, we collect information only insofar as it is and remains necessary to fulfil the purpose of your interaction with us. We collect and store information using a number of technologies such as cookies, caches, databases, and logs. We do not use or disclose personal information other than as described in this Privacy Policy.

You may refuse to provide us with personal information, and you may object to our collection of information, however this may impact your ability to use or benefit from our site, platforms, apps, products, and/or services, and our ability to provide you with support or assistance.

You must not provide us with the personal information about another person unless you have first obtained that person’s prior consent to do so and you have told them their personal information will be handled in accordance with this Privacy Policy (including where to find it).

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Information you provide, content you create, and files you upload

If you create an account on our site and other platforms, including any mobile applications (apps), you may provide us with personal information that includes your name, address, phone number, date of birth, and any other information you may volunteer.

You may opt to provide us with personal information for specific purposes. For instance, you may provide:

• your email address to receive marketing material or updates about our services
• a phone number and/or email address so that we may contact you about an inquiry
• your name and payment information when you purchase a product or service (please note we do not have access to this data, this is handled by a secure third party payment gateway).

We may also collect any content that you may create, upload, or receive from others when using our site and other platforms. This may include comments, messages, documents and pictures.

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Information we collect about your browser and devices

While you use our site and other platforms, we collect general information of the sort that web browsers, servers and network operators typically make available, which may include unique identifiers (e.g. persistent cookies, MAC addresses, device IDs, IMEI numbers), browser type and settings, location data, device type and settings, operating system, IP address, mobile network information including operator name and phone number and application version number, language preferences, crash reports, system activity, and the date, time and referral URL of each visitor request. This information helps us troubleshoot problems, understand how visitors use our site, allocate and balance resources, and improve our products and services.

Some of this information could be personally-identifiable (that is they could be used to directly or indirectly identify you as an individual and natural person)—information like IP addresses, phone numbers, and unique identifiers. We treat such information in the same way that we treat all other personal information (such as your name), and will only use and disclose such personal information as described in this Privacy Policy.

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Information we may collect about how you use our site and services

As you use our site and services, we may collect information about how you interact with our platform and how you use our services (your activity), such as the links that you click, content that you view, terms, products, and services that you search for, products that you buy, people you communicate or share information with.

We may collect information about your activity to understand how you use and interact with our site and other platforms, and our products and services. This helps us to understand customer preferences, optimise our site and other platforms, allocate and balance resources, and improve our products and services.

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How we use the information we collect

We collect information to enable you to receive the benefit of our site, platforms, apps, products, and services. Subject to this Privacy Policy and your data preferences, we may use the information we collect for some or all of the following purposes:

• carry out our obligations and to provide you with agreed products and services;
• secure and protect you, us, our site, platforms, apps, products, and services, and the public;
• establish, maintain and administer your account;
• maintain, troubleshoot, and improve our site, platforms, apps, products, and services;
• measure performance of our site, platforms, apps, products, and services;
• develop new products and services;
• if your preferences permit, to provide you with recommendations and personalised products and services;
• communicate with you about our site, platforms, apps, products, and services—such as to notify of changes and updates, alert you to data or security breaches, and to provide you with customer support;
• with your explicit consent, to create or distribute promotional and marketing material that is relevant to you;
• for quality assurance and training purposes;
• in the case of non-personally identifiable information only—or personal information only with your explicit consent—to promote and market ourselves, our products and services, and our websites (including any social media pages maintained or operated by us such as Facebook, Instagram, Snapchat, Twitter, YouTube etc); and
• meeting our legal, regulatory, and tax reporting obligations; and
• any other uses identified to you at the time of collecting your personal information or as reasonably contemplated by this Privacy Policy and our Website Terms of Use (the Purposes).

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When we share your personal information with others

Personal information we collect stays within the Company, other than in the following circumstances:

• when you give us explicit consent to share your data;
• if we share it with our partners, and other trusted organisations we work with to provide products and services to you;
• when we share it with trusted external service providers and data processors such as data centres, web hosts, cloud storage and cloud software providers, customer support providers, payment processors, debt collectors, accountants, and insurers;
• when we share it with prospective sellers or buyers of our business or assets; or
• if we are obliged to share it with regulators and other relevant parties for the purpose of legal or contractual compliance, reporting purposes, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or the rights of third parties or the public at large.

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Your data rights

Right of access

You may access and review any personal information we hold about you. On your specific request we will be able to, as soon as reasonably possible, provide you with some or all of (as requested) the following information, where available:

• personal data about you that is in our possession or under our control and the source of such data;
• the ways in which your personal data has been or may have been used or processed by us, including the logic behind any automated decisions (if applicable), during the two years preceding the date of the request;
• the ways in which your personal data has been or may have been disclosed by us, and information on to whom or to which categories of recipients such data has been disclosed, during the two years preceding the date of the request;
• how long we expect to hold on to your data, or if specific information is not available, the criteria we use to determine such a time period; and
• the purpose of any use, processing, or disclosure.

However, we reserve the right not to provide you with your personal data or other related information if providing it could reasonably be expected to:

• threaten the safety or physical or mental health of another individual;
• cause immediate or grave harm to your safety, physical or mental health;
• reveal personal data about another individual;
• reveal the identity of an individual who has provided personal data about another individual and the individual providing the personal data does not consent to the disclosure of his identity; or
• affect the prevention, investigation, detection, and prosecution of criminal offences, or of breaches of ethics for regulated professions; or
• be contrary to national and public security, defence needs, or the national interest (including important economic, financial, monetary, budgetary and taxation matters).

If you wish to exercise your right of access, you should contact us at [email protected] and we will respond to your request within a reasonable period after the request is made. We aim to process all requests within a month for simple requests, however complex and/or voluminous requests may take up to three months to process. If we deny you access, we will provide our reason for doing so at the time of your request.

We do not typically charge a fee for reasonable requests for access to your personal information. However, we may charge a reasonable fee, which will be notified to you before we move forward with the request, for time and cost in the following circumstances:

• if an extended amount of time is required to collate and prepare material for you; and
• if you wish to receive and we are able to provide hard copies or physical media (i.e. CDs, USB drives or other storage media).

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Right to rectification and erasure

Please contact us at [email protected] as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete, up-to-date, no longer necessary for the purpose for which it was collected or processed, or lacks a valid legal ground for processing so that we can update your file accordingly. Depending on the circumstance we may change, erase, or block from use any inaccurate, incomplete, or outdated information. We may require documentary proof or evidence for certain requests. We will process any legitimate requests to correct inaccurate data as soon as practicable, and incomplete data within a reasonable time frame, and send the update personal data to other organisations to which the data was disclosed during the year preceding the date of the correction, unless it is impossible, involves disproportionate effort, the other organisations no longer require the corrected personal data for any legal or business purpose, or you otherwise agree that we do not need to resend the corrected information to any other organisation.

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Right to object to the collection of personal data due to your personal situation

You may object to collection of specific personal data on limited grounds due to your personal situation. Please contact us at [email protected] if you wish to make such a request, along with details of your personal situation and your reasons for objection. We will respond to all requests within a reasonable time frame. If we disallow your objection, we will inform you of our reasons for doing so.

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We look after your personal information

Accuracy

We take all reasonable steps within our control to ensure that the personal information we hold about you is accurate. We also take reasonable steps to ensure that the information is complete and up-to-date. However, we also rely on you to advise us of any changes to your personal information.

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Protection of personal data

We take reasonable steps to ensure that your personal information is treated securely and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

Although we aim to create a safe, secure environment by trying to limit access to the site to legitimate users, we cannot guarantee that unauthorised parties will not gain access. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorised access to your personal information.

We will make every feasible effort to inform the authorities within 72 hours of the occurrence of any significant personal data breach which poses a risk to your rights and freedoms as a natural person. We will also inform you without undue delay unless the risk to your individual rights and freedoms is low—such as if the compromised data was well encrypted.

Please contact us at [email protected] immediately if you become aware of any unauthorised use of your account by anyone else or any other breach of security.

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Retention of personal data

We will cease to retain its documents containing personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the Purpose for which that personal data was collected or further processed is no longer being served by retention of the personal data.

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Data transfers

Your information may be processed outside of the country where you live. Regardless of where we use, process, or store your data, we will comply with the protections set out in this Privacy Policy. We will not transfer any personal data to a country or territory outside the European Union except in accordance with the requirements prescribed under the DPA and GDPR to ensure that organisations provide a standard of protection to the personal data transferred that is comparable to the protection under the DPA, GDPR and this Privacy Policy.

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Cookies

To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this too. A cookie is a small text file that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Our site uses cookies to help us identify you from other users, track your usage of our site, and your website access preferences. We do or may use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can control and/or delete cookies as you wish—for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

 

Use of personal information for direct marketing

From time to time we may use the personal information we collect from you to identify particular products and services of ours that we believe may be of interest to you. We may then contact you to let you know about these products and services, new features and how they may benefit you, solicit your feedback, or just keep you up to date with what’s going on with us and our products and services and/or products.

Direct marketing from us generally takes the form of an electronic marketing email. Where we use your personal information to send you marketing information by email, SMS, MMS or other electronic means we may do so with your express or deemed consent. Every directly addressed marketing contact sent or made by us will include a means by which you may unsubscribe (or opt out) of receiving further marketing information. Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. You can contact us at [email protected] to make a request.

 

Links to third party websites

Our site may contain links to and from third party websites. If you click on such links, you do so at your own risk and subject to whatever privacy policy and/or website terms may govern the use of such websites. We have no control over, and are not responsible, nor liable for, the content, privacy practices or website terms of such websites or any information you provide to them. You should read the privacy policy of these third parties to find out how they handle your personal information when you visit their websites.​

 

Privacy complaints

If you believe that we have breached your privacy rights in any way, or you would like to discuss any issues about our Privacy Policy please contact us at [email protected]. All such enquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable, and where appropriate, we will work together with the relevant authority to address your complaint, and/or make improvements to our systems and processes.​

 

Privacy Policy changes

We may change our Privacy Policy from time to time, and in our sole discretion. We encourage you to frequently check our site for any changes to our Privacy Policy. We will not reduce or diminish your rights under this Privacy Policy without your explicit consent. If any changes do not reduce or diminish your rights, your continued use of our site, services, requesting our assistance or the provision of further personal information to us (directly or via an authorised person) after any change in this Privacy Policy will constitute your acceptance of such change. If we make significant changes to this Privacy Policy, we will provide a more prominent notice of the changes, such as by emailing you.

 

If you have any question regarding our privacy policy, please contact us at [email protected]