PRIVACY POLICY

Last Updated: September 23, 2025

Neurofeedback Brain Training ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal data when you interact with our online sales funnel (the "Funnel"), including when you visit our website, submit inquiries, or provide information via forms driven from Facebook ads. We operate from Birmingham, UK, and are the data controller responsible for your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy complies with UK data protection laws and applies to all users in the UK and EEA. By using the Funnel, you consent to the practices described here. If you do not agree, please do not use the Funnel.

1. Information We Collect

We collect personal data to provide and improve our neurofeedback brain training services, which involve non-invasive brain training sessions to enhance cognitive function.

Data you provide directly: Name, email address, phone number, postal address, date of birth, and health-related information (e.g., reasons for seeking brain training, medical history relevant to sessions). This is collected via Funnel forms for booking consultations or services.

Data from Facebook ads: If you click through from ads, we may receive limited data like your Facebook profile ID or ad interaction history (via Facebook Pixel for tracking conversions).

Automatically collected data: IP address, browser type, device information, pages visited, and time spent on the Funnel (using cookies and analytics tools like Google Analytics).

Special category data: Health data (e.g., mental health conditions) is collected only with your explicit consent for service provision, as it falls under "special categories" requiring additional safeguards.We do not collect sensitive data without necessity and always seek explicit consent where required.

2. How We Use Your Information

We use your data for legitimate business purposes, including:

Providing services: To schedule and deliver neurofeedback sessions, send confirmations, and follow up on inquiries (legal basis: contract performance).

Marketing: To send promotional emails about brain training offers, with your consent (legal basis: consent). You can opt out anytime.

Improving the Funnel: Analyzing usage to enhance user experience (legal basis: legitimate interests).

Compliance and safety: For fraud prevention, legal obligations, or health/safety in sessions (legal basis: legal obligation or vital interests).

Health-specific uses: Processing health data for personalized training plans (legal basis: explicit consent and health care provision under UK GDPR Article 9).

3. Sharing Your Information

We share data only when necessary and with safeguards:

Service providers: Processors like email tools (e.g., Mailchimp), payment gateways (e.g., Stripe), or CRM systems, bound by data processing agreements.

Facebook: Limited anonymized data for ad optimization (as a joint controller under Facebook's terms).

Legal requirements: If required by law, regulators (e.g., ICO), or to protect rights/safety.

Business transfers: In case of merger or sale, with notice to you.

We do not sell your data. International transfers (e.g., to US-based providers) use Standard Contractual Clauses for adequacy.

4. Data Security

We use industry-standard measures (e.g., encryption, firewalls, access controls) to protect your data. Health data is stored securely in the UK. However, no system is 100% secure, so we cannot guarantee absolute security.

5. Data Retention

Inquiry data: Retained for 6 months if no service is booked.

Client data: Retained for 7 years post-session (UK tax/health records requirement).

Marketing data: Until you unsubscribe or for 2 years of inactivity.

We securely delete or anonymize data when no longer needed.

6. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

Right of Access: You can request a copy of your personal data. To exercise this right, email us at [email protected].

Right to Rectification: You can request correction of inaccurate personal data. To exercise this right, email us at [email protected].

Right to Erasure: You can request deletion of your personal data, subject to legal retention requirements. To exercise this right, email us at [email protected].

Right to Restriction: You can request that we limit processing of your data during disputes. To exercise this right, email us at [email protected].

Right to Object: You can object to processing for marketing or based on legitimate interests. To exercise this right, use the unsubscribe link in marketing emails or contact us at [email protected].

Right to Data Portability: You can request your data in a machine-readable format. To exercise this right, email us at [email protected].

Right to Withdraw Consent: You can withdraw consent for processing where consent is the legal basis; this does not affect prior processing. To exercise this right, email us at [email protected].

We will respond to requests within 1 month, though this may be extended in complex cases. If you have concerns, you can lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk.

7. Cookies and Tracking

The Funnel uses cookies for functionality, analytics, and ads. You can manage preferences via browser settings. See our Cookie Policy for details (linked in footer).

Essential cookies: Always on for Funnel operation.

Analytics: Google Analytics (opt-out available).

Advertising: Facebook Pixel for retargeting.

8. Children's Privacy

Our services are not for under-18s without parental consent. We do not knowingly collect children's data.

9. Changes to This Policy

We may update this policy; changes will be posted here with the update date. Significant changes will be emailed to registered users.

10. Contact Us

Neurofeedback Brain Training
Birmingham, UK
Email: [email protected]
Phone: 07417 587281
Data Protection Officer: na

For ICO details: www.ico.org.uk.