This is our current Privacy Policy and was Last Revised on the 25th of April 2024.
This website is operated by Project Brains Limited, a private limited company registered in England with company number 13490896 at the address of 4th Floor, Silverstream House 45 Fitzroy Street, Fitzrovia, London, England, W1T 6EB (“we”, “us”, “our”). We are the data controller responsible for your personal information and the company responsible for this website.
Project Brains is an information technology product offered by us. Project Brains is not itself a regulated financial or digital service or product, rather it is a technical method to inform its users about financial or digital services or products. We recognise and respect the importance of maintaining the privacy of any visitors to our website and our clients, and have established this Privacy Policy as a result. Our Privacy Policy is designed to assist you in understanding how we collect and use the personal information you provide to us and to assist you in making informed decisions when using our website.
Please read this privacy and cookie policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information and cookie data. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities should you need to. Please retain a copy for your records. This policy forms part of our Terms and Conditions.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to and comply with the UK General Data Protection Regulation (UK GDPR), the UK Data Protection Act 2018, General Data Protection Regulation, Regulation (EU) 2016/679 (EU GDPR), any laws which implement, replace, extend, re-enact, consolidate or amend such laws, and any other applicable laws.
This Privacy Policy is applicable to the processing by us of all personal information (information that relates to you, directly or indirectly. In particular, it could include information that could identify you by reference to an identifier such as your name or email or an online identifier. It could also include factors specific to a characteristic you have). In general, you may visit our website without identifying yourself or revealing any personal information. However, we collect domain information from your visit to customise and improve your experience on our website.
Below we describe why we might gather personal information from you, what personal information we might collect, how we might collect it and what we might use that personal information for.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below (see ‘Contact us’ below).
Changes to this privacy policy
We may change our Privacy Policy from time to time and we will post those changes on the Project Brains website and change the last updated date in the beginning of this policy so that you are always aware of what personal information we collect and how and why we use it.
What information do we collect?
Personal information, or personal data, 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). A data subject is the individual who the personal information relates to.
Through our website and direct interactions, we may collect and use personal information, including but not limited to:
– basic information relating to your identity – such as your name (including gender title / prefix, first name, middle name, last name and informal name), photo (if you choose to provide this to us) and gender;
– any unique identification number or other similar numerical or coded identifier;
– professional information – such as your organisation’s name and your job title;
– business contact information – such as your work address, email address, and phone/fax number(s);
– individual profile information – including, but not limited to, the nature of your personal interest in or involvement in your organisation’s interest in Project Brains and related services;
– technical information – such as information about the device you use to interact with us (including device identifier, model, operating system and version, IP address, the internet browser you use, the pages you have visited on the Project Brains website, information in relation to your session, the type of device (mobile, smartphone, tablet or any other electronic device) you are using when you visit the website, the temporary or persistent unique device identifiers (UDIDs) placed by us or our service providers, the unique identifier assigned by us to your device, your mobile operating system, information about your visit, including the full uniform resource locators (URL) clickstream to, through and from the website (including date and time); services 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), consultation length(s), recurrence of visits and other interaction information, methods used to browse away from the page);
– personal email preferences – including, but not limited to, whether you have opted to receive emails relating to Project Brains and your marketing communications preferences; and
– correspondence – when you contact us, including, but not limited to, making an enquiry or a request, and any correspondence relating to any such enquiries or requests.
profile data - including your username and password, account date, profile bio, name of the business entity you represent, your business needs, feedbacks, reviews and survey responses, your LinkedIn profile, professional skills, the description text that the user may write about him/herself, the offers and requests the user has posted to the service, business strategies and needs. You are entitled to create an account of your own only and you are strictly forbidden to use any personal data of any other persons while creating your account. If you believe that someone has created an unauthorized account depicting you or your experience, please contact us.
financial data - including your bank account and payment card details.
transaction data - including details about payments to and from you and if you are a specialist as defined in our Terms and Conditions, to be able to make payment to you.
We do not ask for any payment or payment information directly on this website.
This website is not intended for children and we do not knowingly collect personal information relating to children.
How do we obtain your personal information?
We may collect your personal information when you visit our website.
We may combine information that we have about you from various sources, including the information that you have provided to us.
We use different methods to collect personal information from and about you including through:
Direct interactions. We may collect your data through your filling in forms, submitting or uploading information to our website, creating an account and profile, log in to our website, contracting with us to receive our services or you corresponding with us through our website, social media, by phone, email or otherwise, requesting marketing communications to be sent to you, and providing your feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. We collect this data by using cookies and other similar technologies. Please see the section on Cookies below for further details.
Third parties or publicly available sources. We may receive personal information about you from various third parties such as data analytics provider, such as Google or through automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.
How and why do we use your personal information?
We will only use your personal information when the law allows us to. Most commonly, we may use your personal information in the following circumstances:
where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract to make available our services and products
for the establishment, exercise or defence of legal claims or proceedings or
Where it is necessary for our legitimate interests or those of a third party (including to ensure that we are able to maintain its relationships with recipients, prospective recipients and visitors to the website. Using your personal information helps us to operate and improve our business, minimise any disruption to the information that we provide to you, make our communications with you more relevant and personalised to you, and make your experience more efficient and effective) and your interests and fundamental rights do not override those interests.
The list below explains what we use your personal information for and why.
We use your personal information for providing products and services to you and to send you essential information about our services.
To perform our contract with you or to take steps at your request before entering into a contract
We use your personal information to register you and set you up as a new member/user business and to allow you to then interact with our website for the provision of our services to you by us and by the specialists
To perform our contract with you
For our legitimate interest to enable us to better match you with the appropriate services that we may be able to offer to send to you
We use your personal information to register you and set you up as a specialist and to allow you to provide services to businesses and to be able to make payment to you in return for the services
To perform our contract with you
We use your personal information for validating your account and/or to reset your username and password if required and management of your account with us
To perform our contract with you
We use your personal information for operating and improvement of the website and to ensuring that content from the website is presented in the most effective manner for you and your computer or device
To effectively perform our contract with you
For our legitimate interests i.e. to make sure we can deliver the best service to you and respond to you when you need us
We use your personal information for preventing and detecting fraud against you or us and identifying you if you contact us
For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us
We use your personal information for conducting checks to identify our customers and verify their identity
Other activities necessary to comply with professional, legal and regulatory obligations that apply to our businessTo comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, i.e. to minimise fraud and to prevent consumers registering more than one membership in order to exploit our services.
We use your personal information for gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Management of your accounts with us
To perform our contract with you
We use your personal information for Customer service and responding to any queries you raise with us and to provide customer support
To effectively perform our contract with you
For our legitimate interests i.e. to make sure we can deliver the best service to you and respond to you when you need us
We use your personal information for management of promotions
To perform our contract with you
For our legitimate interests or those of a third party, i.e. to study how customers use our products/services, to develop them and grow our business
We use your personal information for ensuring business policies are adhered to, e.g. policies covering security and internet use
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
We use your personal information for ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
We use your personal information for statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
For our legitimate interests i.e. to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
In certain circumstances where you have given your consent
We use your personal information for preventing unauthorised access and modifications to systems
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us
To comply with our legal and regulatory obligations
We use your personal information for updating and enhancing customer records and our service provided to you
To perform our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products or services
Some of the purposes of processing may overlap and there may be several grounds which justify our use of your personal information.
We collect, use, process and disclose personal information in accordance with applicable data protection and privacy laws. We do not collect, use, process, or disclose personal information for any purpose or in any way other than as described in this privacy policy (or, to the extent permitted under applicable data protection and privacy laws, any purpose directly related to, or compatible with, such purpose), unless we are required or permitted by applicable data protection and privacy laws to do so, you are so informed at the time of collection, or we have obtained your consent, directly or indirectly, to use or disclose your personal information for another purpose or in another manner. To the extent permitted by applicable data protection and privacy laws, we may provide your personal information to law enforcement agencies, regulatory bodies, or other government agencies without your knowledge or consent.
Special Category Personal Information
Special category personal information includes personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data (when processed to uniquely identify an individual); and data concerning health, sex life or sexual orientation.
We do not anticipate that we will collect any such data. However, if we do process special category personal information, we will also ensure we are permitted to do so under data protection laws, for example only where:
we have your explicit consent;
the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
the processing is necessary to establish, exercise or defend legal claims.
Marketing
You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal information for marketing purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
contacting us at info@projectbrains.io;
using the ‘unsubscribe’ link in emails; or
updating your marketing preferences by clicking “don’t send me newsletters” on our website from settings, notifications.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal information with the utmost respect and will obtain your express
Your instructions to limit the use of your information will be processed as soon as reasonably practicable and in accordance with applicable law.
With whom do we share your personal information?
We may share certain of your personal information with:
– our other offices;
– your organisation or other individual representatives of that organisation;
– employees and consultants in relevant departments throughout our company;
– third parties that provide products and services to us such as IT systems suppliers and support and cloud servers, website hosts etc.;
– local and foreign legal and regulatory authorities and governments to comply with our legal and regulatory obligations;
– our insurers and our bank
– potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations; or
– consultants, accountants, auditors, lawyers and other outside professional advisors.
All our third-party service providers and other offices will be required to take appropriate security measures to protect your personal information in line with our policies and procedures in force from time to time. Third-party service providers will not be allowed to use your personal information for their own purposes and they will only be permitted to process your personal information for specified purposes and in accordance with our instructions. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
See “How we secure your information” below for more information on how we will keep your personal information secure when sharing it with others.
Transfers of your personal information outside of the UK
Your personal information may be processed by us and third parties described in “With whom do we share your personal information” section above anywhere in the world.
If you are based outside the UK, your personal information may be transferred to the UK as this is where we are based. For our customers based in the UK or European Economic Area (EEA), please be advised that some of these third parties may be based outside the UK or EEA. Under UK and European data protection laws, we can only transfer your personal information to a country or international organisation abroad in certain circumstances. We will ensure that where your personal information is transferred abroad, it does so in accordance with applicable laws.
This may include an adequacy decision being in place in relation to the country that is in receipt of your personal information or we may make an international data transfer impact assessment and then if we are satisfied that your personal information will be protected, we may put into place appropriate safeguards including the use of approved Standard Contractual Clauses, UK addendum and/or International Data Transfer Agreements, where deemed safe. We use WordPress.com, Sharetribe, Namecheap, Hubspot, Cookiebot and Google Cloud as service providers and your personal information may be transferred where these providers are based after putting into place appropriate safeguards.
We may transfer your personal information to certain countries on the basis that UK government has decided the particular country ensures an adequate level of protection of personal data (adequacy decision) These are all European Union countries and countries of the European Economic Area and countries that the UK government has made an adequacy decision in favour of, including, Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Alternatively, a specified transfer exception may apply.
How long is your personal information retained?
We will keep your personal information, as updated from time to time, only for as long as it remains necessary for the purposes for which it was collected (outlined in the “How do we use your personal information?” section above) or as required or permitted by applicable privacy and data protection laws.
To determine the appropriate retention period for personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When it is no longer necessary to keep your personal information, we will delete or anonymise it.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Please note that retention periods will vary depending on the jurisdiction in which your personal information is processed.
Cookies
Our websites use “cookies” to identify the areas of our websites that have been accessed by the device you are currently using. A cookie is a small piece of data stored on your computer or mobile device by your web browser. We use cookies to personalize the content that you see on our websites, by keeping your relevant username in a cookie file after you log in for the current session or longer. We also use third party tools from WordPress.com, Sharetribe, Namecheap, Linkedin, Youtube, Hotjar, Squarespace, Cookiebot and Google that use cookies to identify the areas of our websites that have been accessed by users and also to collect information about user devices (IP address, browser, operating system, requested resources etc.). Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access functionality on our websites correctly or at all. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
We use the following cookies:
Necessary/essential cookies. These are cookies that are required for the operation of our website and without them our website can’t operate properly. As these cookies are necessary for the correct functioning of our Platform, you are unable to control their use from within the cookies management tool.
Analytical and marketing cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily and provide you with a more relevant browsing experience or personalise the content on our site.
Functional cookies. These are used to recognise you when you return to our website and monitor the performance of 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/advertising cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
Some cookies may fulfil more than one of these purposes.
Strictly necessary/essential cookies do not require your consent. We will ask for your consent/permission to place other cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested and/or the functioning of the website. You do not need to allow other than strictly necessary/essential cookies to visit our website. However, enabling them may allow for a more tailored browsing experience.
You can exercise your cookie preferences when you first arrive at our website where you will see a notice with a pop-up about our use of cookies to choose which cookie technologies you wish to allow to access your device before confirming and proceeding. You can also change these settings, customise, manage or withdraw any consent to the use of cookies at any later point by going to trigger displayed at the bottom of the page.
Throughout our website we may also link to other websites owned and operated by certain trusted third parties to, for example, make additional products and services available to you. These other third-party websites may also use cookies or similar technologies in accordance with their own separate policies. For privacy information relating to these other third-party websites, please consult their policies as appropriate.
How we secure your information
We will use appropriate security measures and technologies to help protect your personal information from being accidentally lost, used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have security procedures in place as well as technical and physical restrictions to access to ensure that your personal information is safeguarded at all times.
We have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.
Our personnel handling personal information will also be required to take appropriate measures to maintain, secure and protect the confidentiality of such information and take appropriate precautions to protect personal information from any unauthorised use, disclosure or potential loss.
When we retain a third-party service provider, that provider will be carefully selected in accordance with our policies and procedures and the third-party service provider will be required to use appropriate safeguards in relation to the handling of your personal information (including in relation to maintaining confidentiality of your personal information and implementing appropriate technical and organisational security measures).
Your personal information will only be accessed by those employees, agents, contractors, secondees and other third parties who have a business need to access such personal information. They will only process your personal information on our instructions and they will not be allowed to use personal information for their own personal use or otherwise outside of their engagement with us. In addition, they will be required to use appropriate safeguards in relation to the handling of your personal information (including complying with any rules and policies implemented by us, maintaining confidentiality of your personal information and implementing appropriate technical and organisational security measures).
Whilst we endeavour to protect the privacy of information you provide on our website, we cannot guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of user information. When requesting information or sending forms to us by e-mail, we recommend that you do not include any confidential information (i.e. credit card information). For your protection, our e-mail responses to you will not include any confidential information.
Portions of the website may require registration and log-in processes that need a password. Your password is intended for your sole and individual use. You are responsible for maintaining the confidentiality of your password. All activities that occur using your password are your responsibility. Please immediately notify us of any unauthorised use of your password or your account.
Your rights
You have the following rights in relation to your personal information, which you can exercise at any time:
Access. The right to be provided with a copy of your personal information
Rectification. The right to require us to correct any mistakes in your personal information
Erasure (also known as the right to be forgotten). The right to require us to delete your personal information—in certain situations.
Restriction of processing. The right to require us to restrict processing of your personal information in certain circumstances, e.g. if you contest the accuracy of the data
Data portability. The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object. The right to object:
- at any time to your personal information being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.Not to be subject to automated individual decision making. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
Please note that your rights may vary depending on the jurisdiction in which your personal information is processed.
Where you are given the option to share your personal information with us, you can always choose not to do so. If you object to the processing of your personal information we will respect that choice in accordance with its legal obligations. This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see “How and why we use your personal information” above).
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘Contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
contact us—see below: ‘Contact us’;
provide enough information to identify yourself; and
let us know what right you want to exercise and the information to which your request relates.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.
How to make a complaint
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to make a complaint at any time to your local data privacy supervisory authority. Information Commissioner's Office (ICO), is the UK supervisory authority for data protection issues (www.ico.org.uk). If you are based outside the UK, you may also have the right to submit a complaint to the relevant supervisory authority in your jurisdiction. A list of EU supervisory authorities is available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. We would, however, appreciate the chance to deal with your concerns in the first instance.
Contact us
We welcome your comments and concerns relating to your personal information and this Privacy Policy.
You can contact us and our data protection manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Email address: info@projectbrains.io
Address: 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London W1T 6EB, United Kingdom