Privacy Policy

Last updated on 14/06/2024

INTRODUCTION

Welcome to the privacy policy (the “Privacy Policy”) of REHABSTUDIO LTD (Company number NI054308) with registered office address at Unit 12 Ormeau Business Park, 8 Cromac Avenue, Belfast, Belfast, BT7 2JA and trading address at The Depot 18 Wenlock Road London N1 7TA (“we”, “us”, “our”, or “Rehab”). We respect your privacy and are committed to protecting your Personal Information (as defined below). This Privacy Policy will inform you as to how we collect, process, and use your Personal Information when you visit our website at http://beta.rehab (the “Site”) or any other websites, applications, features, content, software, products, and services offered through our Site and their associated service platforms, including any improvements, developments, or modifications thereto (“Services”).

IMPORTANT INFORMATION AND WHO WE ARE

CONTROLLER

We are the controller and responsible for your Personal Information. We have appointed a data privacy manager (the “DPM”) 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 privacy controls, please contact the DPM using the following details:

Full name of legal entity: REHABSTUDIO LTD
Name or title of Data Privacy Manager: Data Privacy Manager
Email address: modestas.pocius@team.rehab
Postal address: The Depot 18 Wenlock Road London N1 7TA

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our Privacy Policy under regular review so we may update this Privacy Policy from time to time. We will notify you of any material changes. All changes are effective immediately when we post them and we will use reasonable efforts to alert you about any changes by updating the “Last updated” date of this Privacy Policy. By continuing to use the Site or Services after the date such revised Privacy Policy is posted, you will be subject to, and be deemed to have accepted, the changes therein.

It is important that the Personal Information we hold about you is accurate and current. Please contact us if your Personal Information changes during your relationship with us.

THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

“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 (i.e., anonymous data).

We may collect, use, store, and transfer different kinds of Personal Information about you which we have grouped together as follows:

“Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, photographs, age and gender.

“Contact Data” includes billing address, residential address, email address, social media handles and telephone numbers.
“Financial Data” includes bank account and payment card details.
“Transaction Data” includes details about payments to and from you and other details of products and services you have purchased from us.
“Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, full 'Uniform Resource Locators' clickstream to, through and from the Site (including date and time) and other technology on the devices you use to access the Site.
“Profile Data” includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, mouse-overs and methods used to browse away from the page).
“Usage Data” includes information about how you use the Site, products and Services, including but not limited to whole utterances and message intents.
“Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any “Sensitive” or “Special Categories” of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

PROVISION BY YOU OF PERSONAL INFORMATION ON BEHALF OF OTHERS

Where you are providing Personal Information to us on behalf of another individual or individuals (for example, on behalf of an organization when providing employee details), in doing so you are making a declaration that you have: (i) been duly authorized by each such individual to disclose such Personal Information to us for the purposes detailed hereunder; and (ii) explained, notified, and provided copies of this Privacy Policy to all data subjects on whose behalf you are providing information.

HOW IS YOUR PERSONAL INFORMATION COLLECTED

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

Direct interactions. You may give us your Identity Data, Contact Data, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes Personal Information you provide when you:some text
- apply for our products or Services;
- create an account on the Site (including any of our apps);
- subscribe to our Service or publications;
- request marketing to be sent to you;
- enter a competition, promotion, or survey;
- give us some feedback; or
- enter information or agree to usage of your data in one of our applications.
Automated technologies or interactions. As you interact with the Site, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this Personal Information by using cookies, server logs, and other similar technologies. Please see our cookie policy below for further details.

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IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

Where we need to collect Personal Information 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.

HOW WE USE YOUR PERSONAL INFORMATION

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

Delivery of Services. We may use your Personal Information in order to achieve our legitimate business interest of delivering Services you request or to fulfill contractual obligations to you.
Performance of a Contract. Where we need to perform the contract we are about to enter into or have entered into with you.
Direct Marketing. With your consent, we may use your Personal Information to send you our related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications by following the unsubscribe link at the bottom of our marketing communications.

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Site Optimization. We use analytics and search engine providers to assist us in the improvement and optimization of our Services and provide information to providers such as Google for these purposes.
Compliance with Legal or Regulatory Obligation. We may use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

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For Compliance, Fraud Prevention, and Safety. We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.

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For Any Other Purpose You Consent To At The Time Of Collection. Provided that if we intend to subsequently use your Personal Information for a different purpose, we will obtain your consent for such different purpose.

Please contact us to find out more about the types of lawful basis that we will rely on to process your Personal Information.

CHANGE OF PURPOSE

We will only use your Personal Information 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 Information 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 Information without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.
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DISCLOSURES OF YOUR PERSONAL INFORMATION

We may have to share your Personal Information with the parties set out below for the purposes set out in the table above:

Service Providers. We share your Personal Information with service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above (e.g., information technology services, information storage and security, payment processing, fraud detection, marketing management and communications, customer service functions, statistical analysis).

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Affiliated Companies. We may also share your Personal Information with our subsidiaries, affiliates and other related companies for purposes consistent with this Privacy Policy and providing you with our Services.

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Business Reorganization. We may share your Personal Information with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information would be transferred as an asset of Company.

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Mandatory Disclosures and Legal Rights. We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other legal or governmental request for information. We also share Personal Information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims..

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

We do not sell your Personal Information and will not do so in the future without providing you with notice. We may disclose your Personal Information for the following purposes, which are not a sale: (i) if you direct us to share your Personal Information, (ii) disclosures as part of a merger or asset sale, and (iii) as otherwise required or permitted by applicable law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your Personal Information.

DATA COLLECTED FROM MINORS

Our Services are not intended for and shall not be used by anyone under the age of 18. Additionally, we do not knowingly solicit data from or market to children under 13 years of age. If we learn that Personal Information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any Personal Information we have collected from children under age 13, please contact us at: [EMAIL].

AUTOMATED DECISION MAKING

We do not use your Personal Information to make automated decisions.

MARKETING

We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising. For more information on how we market, please see paragraphs below.

PROMOTIONAL OFFERS FROM US

We may use your Identity Data, Contact Data, Technical Data, Usage Data, and Profile Data 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 or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that Marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your Personal Information with any third party company for Marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you Marketing messages at any time by following the opt-out links on any Marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these Marketing messages, this will not apply to Personal Information provided to us as a result of a product/service purchase, product/service experience, or other transactions.

COOKIES

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 Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the EEA so their processing of your Personal Information will involve a transfer of data outside the EEA. Such destinations may not have laws which protect your information to the same extent as in the EEA. Whenever we transfer your Personal Information out of the EEA, 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 Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Information in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Information to third countries.
Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism we used when transferring your Personal Information out of the EEA.

DATA SECURITY

While no data transmission is guaranteed to be 100% secure, we have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized 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.
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THIRD-PARTY WEBSITES AND CONTENT

You may be sent or linked to other websites (“Third-Party Websites”) as well as articles, photographs, text, graphics, pictures, designs, music, sound, video, information, and other content or items belonging to or originating from third parties (“Third-Party Content”). Such Third-Party Websites and Third-Party Content are not investigated, monitored, or checked for accuracy, appropriateness, or completeness by Company, and we are not responsible for any Third-Party Websites accessed through the Services or any Third-Party Content posted on, available through, including the content, accuracy, offensiveness, opinions, reliability, privacy practices, or other policies of or contained in the Third-Party Websites or the Third-Party Content. Inclusion of, linking to, or permitting the use of any Third-Party Websites or any Third-Party Content does not imply approval or endorsement thereof by Company. If you decide to leave the Services and access the Third-Party Websites or to use any Third-Party Content, you do so at your own risk. You should review the applicable terms and policies, including privacy and data gathering practices, of any website to which you navigate from the Services. Any purchases you make through Third-Party Websites will be governed by the terms and conditions of the applicable website provider, and Company takes no responsibility whatsoever in relation to such purchases. You acknowledge that Company does not endorse the products or services offered on Third-Party Websites and you shall hold Company and its affiliates harmless from any harm caused by your purchase of such products or services. Additionally, you shall hold Company and its affiliates harmless from any losses sustained by you or harm caused to you relating to or resulting in any way from any Third-Party Content or any contact with Third-Party Websites.
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YOUR PRIVACY CONTROLS

We put our customers first and respect your ability to exercise your privacy rights and choices. Where possible, we give you control over the Personal Information we collect about you, to ensure it is accurate and reflects your preferences. This Section describes key controls for managing your privacy across our Services. You may request the follow as it pertains to any Personal Information we collect:

Request Deletion. You may request that we delete any Personal Information about you that we maintain.

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Request Correction. You may request that we correct any inaccurate Personal Information that we maintain.
Know What Personal Information is Being Collected. You may request that we inform you of the (i) categories of Personal Information we have collected about you; (ii) categories of sources from which any Personal Information is collected; (iii) business or commercial purpose for collecting, selling, or sharing any Personal Information we have collected about you; and (iv) categories of third parties to whom we have disclosed any Personal Information. The categories of Personal Information collected over the past 12 months and the categories of sources from which we collect Personal Information are outlined in the Section above entitled "THE INFORMATION WE COLLECT ABOUT YOU” and “HOW IS YOUR PERSONAL INFORMATION COLLECTED.” The business/commercial purpose for the collected information is outlined in the Section above entitled “HOW WE USE YOUR PERSONAL INFORMATION.” The categories of third parties to whom we have disclosed any Personal Information is outlined in the Section above entitled “DISCLOSURES OF YOUR PERSONAL INFORMATION.”

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Access the Personal Information We Collect. You may request a copy of the Personal Information that we have collected and maintained in the period that is 12 months prior to the request date.

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Know What Personal Information is Being Sold. You may request the (i) categories of Personal Information that we have sold or shared to a third party and the category of the third party to whom we sold or shared your Personal Information; and (ii) categories of Personal Information we have disclosed to a third party for a business purpose and the category of the third party to whom we disclosed your Personal Information. The categories of third parties to whom we have disclosed any Personal Information is outlined in the Section above entitled “DISCLOSURES OF YOUR PERSONAL INFORMATION.” We do not sell your Personal Information to third parties and have not sold Personal Information in the preceding 12 months.

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Opt Out of Profiling and Targeted Advertising. You may opt out of the processing of your Personal Information obtained from your activities on non-affiliated websites or online applications for the purposes of targeted advertising.
Opt Out of Sale and Sharing. To the extent we sell or share Personal Information, you may direct us to opt out of that sale or sharing. We do not sell your Personal Information to third parties and have not sold Personal Information in the preceding 12 months.
Restrict Processing of Personal Information. You may request that we restrict the Processing of your Personal Information, under certain conditions with exceptions provided for by applicable data privacy laws.
Object to Processing of Personal Information. You may object to our processing of your Personal Information, under certain conditions with exceptions provided for by applicable data privacy laws.
Opt-Out of Sharing Personal Information with Third Parties for Marketing Purposes. You may opt-out of a company’s disclosure of Personal Information to third parties for its direct marketing purposes, to the extent we disclose your Personal Information to third parties for such purposes. It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes.
Request Data Portability. You may request that we transfer the Personal Information that we have collected to another organization, or directly to you, under certain conditions with exceptions provided for by the applicable data privacy laws.
Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the use of your Personal Information to only uses that are necessary to perform the services or provide the goods.

EXERCISING YOUR PRIVACY CONTROLS

If you have us with your Personal Information, you may request the above by submitting a verifiable consumer request to us by email at newbusiness@rehabagency.ai.

Under applicable data privacy laws, you may also designate an authorized agent to make these requests on your behalf. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued ID, to verify your identity before processing your request to protect your information. In most cases, we will facilitate your request through automated tools available through your password-protected account.

We cannot respond to your request if we are unable to verify your identity or authority. Your verifiable request must include the reference “Request for Privacy Information” in the subject line and the body of the message must: (a) provide sufficient information that allows us to reasonably verify that you are the person whose Personal Information we have collected; (b) describe your request with sufficient detail; and (c) include an email address or mailing address, as applicable, for us to send our response. Such requests will be processed in line with applicable data privacy laws.

We strive to respond to verifiable consumer requests within 30 days; however, if we require an extension (up to an additional 60 days) we will inform you of this extension and the reason in writing. Data disclosure request will only include data collected within the 12-month period preceding the receipt of the verified request. We do not charge a fee to process requests to exercise your rights unless the requests are found to be excessive, repetitive, or unfounded.

Although we make good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual's privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.

If you are a citizen of the European Union, Switzerland, or the United Kingdom, you have the right to make a complaint at any to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to deal with your concerns before you approach the appropriate supervisory authority so please Contact Us in the first instance.

CONTACT US

If you have any questions or comments about the processing of your Personal Information, you may contact us at newbusiness@rehabagency.ai.

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