Privacy Policy

1. Introduction

NeuroBit LTD ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our connectivity infrastructure services.

This policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Information You Provide

We collect information that you provide directly to us, including:

• Account Information: Name, email address, company name, business address, phone number
• Business Information: Company registration details, VAT number, business type
• Payment Information: Billing address, payment method details (processed by third-party payment processors)
• Communication Data: Correspondence, support requests, and feedback

2.2 Information Automatically Collected

When you use our Services, we automatically collect:

• Usage Data: Data volume, connection times, service usage patterns
• Technical Data: IP addresses, device information, connection metadata
• Log Data: System logs, error reports, performance metrics
• Website Data: Cookies, analytics data, browsing information (see Cookie Policy)

2.3 Information We Do NOT Collect

3. How We Use Your Information

Purpose	Legal Basis (UK GDPR)
Providing and managing Services	Contract Performance (Art. 6(1)(b))
Processing payments	Contract Performance (Art. 6(1)(b))
Customer support and communications	Contract Performance & Legitimate Interest (Art. 6(1)(b)(f))
Network security and fraud prevention	Legitimate Interest (Art. 6(1)(f))
Compliance with legal obligations	Legal Obligation (Art. 6(1)(c))
Service improvement and analytics	Legitimate Interest (Art. 6(1)(f))
Marketing (with consent)	Consent (Art. 6(1)(a))

4. Information Sharing and Disclosure

4.1 Service Providers

We share information with trusted third-party service providers who assist us in operating our business:

• Network Providers: Vodafone UK (infrastructure services)
• Payment Processors: Secure payment processing services
• Hosting Providers: Cloud infrastructure and data storage
• Analytics Services: Service performance and usage analytics

All service providers are contractually bound to protect your data and use it only for specified purposes.

4.2 Legal Requirements

We may disclose information when required by law or in response to:

• Valid legal process (court orders, subpoenas, warrants)
• Requests from law enforcement or regulatory authorities
• National security requirements
• Protection of our rights, property, or safety

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

4.4 Partner Relationships

For B2B partners and resellers, we share limited information necessary to provide and manage Services. Partners have their own privacy obligations to their end users.

5. Data Retention

We retain personal data only as long as necessary for the purposes set out in this policy:

• Account Data: Duration of business relationship plus 6 years (for legal/tax purposes)
• Usage Logs: 12 months (unless longer retention required by law)
• Communication Records: 3 years
• Financial Records: 6 years (UK tax law requirement)
• Technical Logs: 90 days to 12 months (security and troubleshooting)

6. Your Data Protection Rights

Under UK GDPR, you have the following rights:

6.1 Right of Access

You can request a copy of your personal data we hold.

6.2 Right to Rectification

You can request correction of inaccurate or incomplete data.

6.3 Right to Erasure

You can request deletion of your data in certain circumstances.

6.4 Right to Restrict Processing

You can request limitation on how we use your data.

6.5 Right to Data Portability

You can request transfer of your data to another service provider.

6.6 Right to Object

You can object to processing based on legitimate interests or for marketing purposes.

6.7 Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data:

• Encryption: Data encrypted in transit (TLS/SSL) and at rest
• Access Controls: Strict authentication and authorization protocols
• Network Security: Firewalls, intrusion detection, and monitoring
• Regular Audits: Security assessments and vulnerability testing
• Staff Training: Regular data protection and security training
• Incident Response: Procedures for data breach detection and response

While we strive to protect your data, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

8. International Data Transfers

Our Services are provided from the United Kingdom. We primarily process data within the UK and EEA. If we transfer data internationally, we ensure adequate protection through:

• Standard Contractual Clauses (SCCs) approved by the UK ICO
• Adequacy decisions for approved countries
• Other lawful transfer mechanisms under UK GDPR

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies. We use:

9.1 Essential Cookies

Required for website operation (session management, security)

9.2 Analytics Cookies

Help us understand website usage and improve user experience

9.3 Functional Cookies

Remember your preferences and settings

You can control cookies through your browser settings. Blocking certain cookies may affect website functionality.

10. Children's Privacy

Our Services are intended for businesses and are not directed to individuals under 18. We do not knowingly collect information from children.

11. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for the privacy practices of other websites. We encourage you to review their privacy policies.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email or prominent notice on our website. The "Last Updated" date will reflect the most recent revision.

13. Data Protection Officer

For privacy-related queries or to exercise your rights, contact our Data Protection Officer:

Email: info@neurobitlab.com

14. Supervisory Authority

You have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner's Office (ICO)
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113
Website: ico.org.uk

By using NeuroBit's Services, you acknowledge that you have read and understood this Privacy Policy.