Last updated: 18 January 2020

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Who is Elementary-AI?

 

Elementary-AI is a brand owned by nuaxia Limited.  nuaxia Limited is a company registered in England and Wales with registered number 10091312 and whose registered office is at 5 Walpole Avenue, Richmond, Surrey, TW9 2DJ (the Company).

Your Acceptance

 

By using or accessing our Website or Services, you are agreeing to this Privacy Policy.

 

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY CEASE ACCESSING OUR WEBSITE OR USING OUR SERVICE.

 

What type of information do we collect?

 

We may collect both Personal Data and data that does not identify you personally (“non-personal Data”).

Examples of personal data include your name, email address, video or voice recordings and location data.

Examples of non-personal data includes your survey responses.

 

What is our legal basis for processing Personal Data?

 

We process personal data under three legal bases: information in the public domain, legitimate interest for business purposes and informed explicit consent.

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How do we collect the information?

 

INFORMATION SUBMITTED OR PROVIDED TO US

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You will provide information to us at various stages including information in order to process registration, orders, invoicing, account settings and profiling data.

 

We may collect data as part of your interaction with us on the Client support or Member help services.

 

We may also collect information about you through other methods such as events, meetings, promotions, conferences, telephone calls, emails and demo requests.

 

Information you provide, for example with Media Responses such as video, audio or picture responses to us may include Personal Data, for example in the form of an identifiable image of you.  You should only record yourself in these responses and no other individuals unless you have obtain their consent in writing using the nuaxia permission form.

 

INFORMATION COLLECTED FROM THIRD PARTIES

 

nuaxia may collect both Personal and non-Personal information from third parties, including but not limited to information service bureaus, data brokers, social media platforms, industry conference or event organisers.

 

INFORMATION COLLECTED THROUGH AUTOMATED PROCESSES

 

We collect data indirectly or passively when you interact with us

• Usage data. This includes recording the webpages you visit, what you click on, when you performed those actions etc. We keep log files that contain data about the nature of each access, including originating IP addresses, operating system versions, and timestamps.

• Device data. We record data about the device and application you use to access our services, such as your IP address, operating system version, device type, system and performance information, and browser type.

• Referral data. If you arrive at our Website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.

• Digital Fingerprinting. nuaxia may use "digital fingerprinting", a technology used to place a unique identifier on a device such or a computer or smartphone. nuaxia digital fingerprinting will never change the functionality of a device, collect otherwise confidential information, log keystrokes, record User activities, take control of the device, or act as malware, adware, a virus or a Trojan. nuaxia may however use digital fingerprinting to match the device ID to the Company accounts logged into from the device and /or to ensure the integrity of the market research results obtained by nuaxia, and to help prevent illicit or illegal use of the Website. nuaxia uses commercially reasonable efforts to ensure that this digital fingerprinting technology is safe, secure and does not cause egregious privacy or data security risks

• Cookies. nuaxia uses cookies, web beacons, clear gifs and similar technology to customise your visit to the Service and for other purposes to make your visit more convenient or to enable us to enhance our Website and Service. You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences, in which case you may still use our Service, but it may interfere with some of its functionality. We do not use cookies to automatically retrieve Personal Data from your computer without your knowledge.

• Activity recording. Nuaxia may record how you use the Website and its Services. This enables us to improve the service and deal with help requests.

• Locational data. Locational data means data which reveals the geographic location of you and your mobile device, where you have given us your consent to collect such information. When you first download one of our Applications, you will be asked if you agree to your location information being disclosed to us. If you consent, then we will collect and transmit this information on a semi-continuous and passive basis, which does not require any further activation on your part. If you wish at any stage to turn off this passive location tracking, you can restrict this in most smartphones under location settings.

• Information from third parties. We may collect your personal information or data from third parties if you have given permission to those third parties to share your information with us. For example, you have the option of registering and signing into the Website with your LinkedIN account details. If you do this, the authentication of your logon details is handled by LinkedIN and we only collect information about your LinkedIN account that you expressly agree to share with us at the time you give permission for your nuaxia account to be linked to your LinkedIN account.

• Information from page tags. We use third party tracking services that employ cookies and page tags to collect aggregated and anonymized data about visitors to our Website. This data includes usage and user statistics.Emails sent by nuaxia through our Service may include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We do this to measure the performance of email messaging and to learn how to improve email deliverability and open rates.

 

How we use the information collected

 

We may use your Personal Data and other information we store about you to:

• contact you in response to Client support or Member help service requests;

• contact you for sales and marketing purposes. For example, about our services which we believe may be of interest to you, to provide you with news and updates about our company or to send you information which may be of interest;

• create new or improved services, features, content or similar activities;

• improve the relevance of the Services we provide;

• allow our suppliers to provide elements of our Service. For example, payment processors, hosting services, email services and web traffic tools;

• identify you to your organisation where the email you have provided is controlled by that organisation;

• provide aggregated, non-identified products and services;

• respond to legal requests, prevent harm or comply with regulations such as Adverse Event reporting.

• enforce our Terms of Use and this Privacy Policy

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CORRECTION OR UPDATING OF YOUR INFORMATION

 

You may inspect, correct and/or update your personal information though your portal access.  In addition, you may email us. For Members, please email us at help@elementary-ai.com. For Clients and all other inquiries, please email us at support@elementary-ai.com.

 

How do we share your information?

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SURVEYS AND VIDEO INTERVIEWS

 

We do not share personal details of Members like name and contact details with Clients using the Website to conduct Surveys. Information shared in this regard will be anonymised. If you have given us a Media Response or participated in a recorded Video Interview, these are supplied to Clients under strict confidentiality and privacy terms.

 

SUPPLIERS

 

We may share your data with third party suppliers who provide services to support nuaxia’s business. We require any third party with access to Personal Data to comply with the terms of this Privacy Policy, to limit their access to any personal information to the minimum necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us.

 

CORPORATE ACTIVITY

 

Information may be transferred to a third party as a result of a full or partial sale, acquisition, merger or as a result of bankruptcy, liquidation or re-organisation.

 

LEGAL REQUIREMENTS

 

We may to access and/or disclose Personal and non-Personal Data we gather as required by courts or administrative agencies and to the extent required to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Terms Of Use, Privacy Policy or the rights of third parties or to investigate any suspected conduct which we deem improper.

 

ADVERSE EVENT REPORTING

 

Where a potential adverse event has arisen within a Member’s response to a Survey or Video Interview, we are required to share name and contact details of the respondent and/or name and contact details of the primary treating physician in the case of a Patient with the Client for the purpose of allowing the Client to make proper inquiries.

 

Where is your information stored?

 

nuaxia securely stores your data within the EU.  If nuaxia’s clients move your data out of the EU, they are obliged to ensure it is EU-US Privacy Shield Framework compliant and they must comply with the terms of the consents which you provide.

 

SECURITY

 

The security of your Personal Data is very important to us. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. However, due to the inherent nature of the internet, we cannot guarantee that communications between you and us or information stored on the Website or our servers, will be completely free from unauthorised access by third parties such as hackers and by using this Website and/or Service, you are entirely and solely assuming this risk.

 

For further information about Security, please see our Security Policy.

 

Opt-out

 

If you no longer wish to participate in surveys or video interviews, then you can unsubscribe by (i) logging into your nuaxia account and selecting unsubscribe in your profile settings; or (ii) clicking unsubscribe in your email footer; or (iii) by sending an email to help@elementary-ai.com including details of your name and physician identification number in the case of an HCP Member.

 

We will process your request in a reasonable amount of time.   We will only be able to amend our own records and will request amendments by any appropriate third party if relevant.

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You have the right to withdraw your consent to participate in market research at any time by contacting us on help@elementary-ai.com .  If you have been referred to nuaxia by a third party please contact them directly.

 

Request access or amendments to your information

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Clients and Members may access their information though the Website. In addition, you may request access or amendments to your Personal Data by emailing us. For Members, please email us at help@elementary-ai.com. For Clients and all other inquiries, please email us at support@elementary-ai.com. We will respond in a reasonable timeframe. We are entitled to restrict access in some circumstances (e.g. if your access would have an unreasonable impact on the privacy of other individuals).

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Right of Deletion

 

Where we are not holding data due to legitimate interest, you have the right to request that data to be deleted.  If you wish this data to be deleted, you can email us to request this at help@nuaxia.com.  If you have been referred to nuaxia by a third party please contact them directly.

 

Third Party use of our Website services

 

Third Parties may use our Website and the Service. They are bound to this Privacy Policy. Whilst nuaxia has no liability to you if they are in breach of the Privacy Policy, we will seek to enforce it for your benefit.

Links to other websites

 

The Website and Services may include links to other third party websites. We are not responsible for the privacy policies and practices of such third party websites.

 

How long do we retain Personal Data?

 

We will retain Personal Data in our active systems whilst you have an account with us or to comply with legal requirements, resolve disputes, enforce our agreements or to support our legitimate interest. Data that is deleted from our active systems will remain within our back-up systems for a minimum of 12 months in accordance with our data security policies at that time.  nuaxia stores your survey or video interview data for a maximum of 6 years in line with our contractual obligations with our clients and for auditing purposes as honorarium will be paid for your responses.

 

Terms of Use

 

The Elementary-AI Terms of Use are incorporated into and shall govern this Privacy Policy, including the use of defined terms herein. Your acceptance of this Privacy Policy shall constitute your acceptance of the Terms of Use.

 

Updates to this Policy

 

We may update our Privacy Policy at any time. We will post those changes to this Privacy Policy, the link to which can be found in the footer to our home page at nuaxia.com.

 

We reserve the right to modify this Privacy Policy at any time.  As a Member, for each new engagement with us, you will always be provided with a link to our current Privacy policy.

Users based outside of the United Kingdom

 

If you are a User accessing the Website from outside of the United Kingdom or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United Kingdom laws, please be advised that through your continued use of the Website and/or Services, which are governed by English law and this Privacy Policy, you are transferring your personal information to the United Kingdom and you consent to that transfer.

 

English Versions

 

Non-English translations of this Privacy Policy are for your convenience only. In the event of any ambiguity or conflict between translations, the English (UK) version shall prevail.

 

Contact and Notices

 

Please email us at support@elementary-ai.com.

 

All notices should also be sent to:

Data Protection Officer

nuaxia Limited

5 Walpole Avenue

Richmond

Surrey TW9 2DJ

United Kingdom

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