Welcome to Neurometry Ltd’s (“Neurometry”) privacy policy.
Neurometry respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice tells you what to expect us to do with the personal information we collect / when you use our services, including our App. It applies to everyone who uses our application, whether you:
Personal information is any information that can be used to identify a living person.
This notice is split into the following sections:
We have used links to help you get to the information you are interested in.
In some places we have provided links to other websites, for example the Information Commissioner’s Office website. We are not responsible for the accuracy of any other website.
Consent to installation of the App
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided below and it is important that you read that information.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this policy.
YES I consent to the installation of the App for the purposes of assisting clinically qualified, medical professionals in diagnosing, monitoring and treating mild forms of cognitive impairment.
NO I do not consent to the installation of the App.
How you can withdraw consent
Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us (our contact details can be found at www.neurometry.io) but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
Neurometry is committed to protecting your personal data and respecting your privacy.
This policy (together with our end-user licence agreement as set out at www.neurometry.io (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:
This policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: Neurometry Mobile application privacy policy.pdf.
Our details
Full name of legal entity: Neurometry Ltd
Email address: info@neurometry.io
Postal address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
Telephone number: +442030053393
What does Neurometry use my personal information for?
We use your personal information to:
This may include using your medical information, so we can offer services that are relevant to you. For example, we may ask you some questions relating to your general health, or you may choose to share your data from wearable devices, monitors or other apps with us. If you are paying for Neurometry services yourself or receiving Neurometry services as a benefit through a third party and we hold your medical data, you may also choose to allow us to use this to personalise recommendations from Neurometry.
You can control how we use your personal information through your communication preferences. You can find your communication preferences within the App or website under ‘Your Account’. From here you can choose the communications you would like to receive from us. You can switch these on or off any time.
And if you receive Neurometry’s services through your NHS GP or private healthcare professional
And if you are paying for Neurometry’s services yourself or receiving them as a benefit through a third party
If you are paying for Neurometry’s services yourself or receiving them as a benefit through a third party, we may also use your personal information to:
If you would like more information on:
this can be found in the Credit Reference Agency Information Notice at https://www.experian.co.uk/crain/index.html.
If you are paying for Neurometry services yourself, we will also use your information to obtain payment from you for our services
If you are receiving Neurometry services as a benefit through a third party, we may also use your personal information to check that you are entitled to this benefit
Under data protection laws, each purpose for which we use your personal information must comply with one of the conditions for processing. You can find out more about the conditions we rely on below:
The Information Commissioner’s Office (ICO) is responsible for ensuring that organisations comply with data protection rules. You can find out more about what the conditions for processing are on their website:
When we are using personal information, we must meet one of the conditions set out in Article 6 of the UK General Data Protection Regulation (GDPR).
Under the GDPR there is some personal information that is so sensitive that it gets extra protection. This special category data is any personal information about someone’s:
It also includes genetic data and biometric data if that information is used to identify an individual.
When we are using special category data, we must also meet one of the conditions set out in Article 9.
We have set out in the table below which conditions we are relying on when we use your personal information.
We have set out below the conditions that we are relying on in order to use your data.
| PURPOSE | ARTICLE 6 CONDITION | ARTICLE 9 CONDITION |
| All patients | ||
| co-operate with regulators, like the MHRA or CQC | Article 6(1)(e) – public task Article 6(1)(c) – compliance with a legal obligation | Article 9(2)(g) – substantial public interest |
| comply with a legal obligation, like a court order requiring us to release information | Article 6(1)(c) – compliance with a legal obligation | Article 9(2)(f) – establishment, exercise or defence of legal claims Article 9(2)(g) – substantial public interest |
| deal with disputes and legal claims, for example if you make a legal claim against one of the professionals utilising our App | Article 6(1)(f) – legitimate interests (we have a legitimate interest in being able to deal with disputes and legal claims) | Article 9(2)(f) – establishment, exercise or defence of legal claims |
| deal appropriately with any risk to public health | Article 6(1)(e) – public task Article 6(1)(c) – compliance with a legal obligation | Article 9(2)(h) – healthcare and social care purposes Article 9(2)(i) – public health |
| Patients receiving Neurometry’s services through their NHS GP or other private healthcare professional | ||
| provide you with Neurometry services | Article 6(1)(e) – public task | Article 9(2)(h) – healthcare and social care purposes Article 9(2)(g) – substantial public interest |
| help maintain the quality of and improve Neurometry services | Article 6(1)(e) – public task Article 6(1)(f) – legitimate interests (we have a legitimate interest in maintaining and improving the quality of Neurometry services) | Article 9(2)(h) – healthcare and social care purposes Article 9(2)(g) – substantial public interest |
| Provide information back to your healthcare professional | Article 6(1)(e) – public task | Article 9(2)(h) – healthcare and social care purposes Article 9(2)(g) – substantial public interest |
| We may also use your information to help other organisations delivering NHS, private or social care to provide you with services. | Article 6(1)(e) – public task | Article 9(2)(h) – healthcare and social care purposes Article 9(2)(g) – substantial public interest |
| let you know more about our services and offers | Article 6(1)(a) – consent | Article 9(2)(a) – consent |
| let you know more about the products and services of third parties that may be relevant to you | Article 6(1)(a) – consent | Article 9(2)(a) – consent |
| Patients paying for Neurometry services themselves | ||
| provide you with Neurometry services | Article 6(1)(b) – performance of a contract | Article 9(2)(h) – healthcare and social care purposes |
| help maintain the quality of and improve Neurometry services | Article 6(1)(f) – legitimate interests (we have a legitimate interest in maintaining and improving the quality of Neurometry services) | Article 9(2)(h) – healthcare and social care purposes |
| carry out identity/soft credit checks | Article 6(1)(b) – performance of a contract | No special data used |
| obtain payment from you for our services | Article 6(1)(b) – performance of a contract | No special data used |
| let you know more about our services and offers | Article 6(1)(a) – consent | Article 9(2)(a) – consent |
| let you know more about the products and services of third parties that may be relevant to you | Article 6(1)(a) – consent | Article 9(2)(a) – consent |
| Patients receiving Neurometry services as a benefit through a third party | ||
| provide you with Neurometry services | Article 6(1)(b) – performance of a contract | Article 9(2)(h) – healthcare and social care purposes |
| help maintain the quality of and improve Neurometry services | Article 6(1)(f) – legitimate interests (we have a legitimate interest in maintaining and improving the quality of Neurometry services) | Article 9(2)(h) – healthcare and social care purposes |
| carry out identity/soft credit checks | Article 6(1)(b) – performance of a contract | No special data used |
| let you know more about our services and offers | Article 6(1)(a) – consent | Article 9(2)(a) – consent |
| let you know more about the products and services of third parties that may be relevant to you | Article 6(1)(a) – consent | Article 9(2)(a) – consent |
There are extra rules that apply to information about criminal allegations and convictions. We do not use this type of information very often, for example you might tell us about a drug-related conviction or time in prison. Our use complies with Article 10 of the GDPR because it meets the condition set out in the Data Protection Act 2018, Schedule 1, Part 1, paragraph 2 (health or social care purposes).
How does Neurometry get my personal information?
Most of the personal information we use is provided to us directly by you so that you can access our services. For example, you provide us with your contact details. Please let us know if there are any changes to your personal details while you are registered with us
This includes personal data you provide when you:
We may use information about your health from health technology companies
If you agree, we may use information about your health from programmes like Microsoft HealthVault or Google Health that individuals use to collect, store and analyse information about their health.
If you agree, we may use information about your health from smart devices. For example, smart watches can keep a record of your heart rate. You can choose to stop sharing this data with us at any time.
We also gather technical information about your visit, like what device you are using to access Neurometry services. More detail about what we collect is set out in the section below (What personal information about me does Neurometry use?)
We automatically collect this personal data by using cookies, server logs, application data caches, browser web storage and other similar technologies. We may also receive data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.
If you get Neurometry services through your NHS GP or private healthcare professional, then we will access information about you that is stored on your records. We will ask for your agreement before we do this.
We access NHS systems so that we can see your full medical record. This means that we can see any information that your NHS GP can see. This will include contact information and detailed health information like family health history, past diagnoses, treatment plans, medication, body measurements and test results.
If you get Neurometry services through your NHS GP or private healthcare professional, then the medical record of your appointment (including any diagnosis or treatment prescribed by the Neurometry GP) will be stored in your medical record.
The medical professionals working with Neurometry and its App log the following information with Neurometry:
If you pay for Neurometry services yourself, we may access information about you from credit referencing agencies, advertising networks and partner organisations that help us process payments.
If you receive Neurometry services as a benefit through a third party then your third-party service provider may provide us with your work contact details like your full name and email address and we may access information about you from credit referencing agencies
If you pay for Neurometry services yourself or you are receiving Neurometry services as a benefit through a third party you will provide us with information about your health (because we are not able to access this information from NHS records). Professional’s utilising Neurometry store the medical record of your appointment (including any diagnosis or treatment prescribed) on our systems.
Please note that if you access our service using your NHS login details, the identity verification services are managed by NHS England. NHS England is the controller for any personal information you provided to NHS Digital to get an NHS login account and verify your identity, and uses that personal information solely for that single purpose. For this personal information, our role is a “processor” only and we must act under the instructions provided by NHS England (as the “controller”) when verifying your identity. To see NHS England’s Privacy and Cookies Policy and Terms and Conditions, please click here. This restriction does not apply to the personal information you provide to us separately.
Recording consultations
Consultations in the course of providing a Neurometry Service may be recorded for quality, training and monitoring purposes. Recordings may include audio, video or both and information collected includes health and medical information and other personal data contained in consultation recordings. If you get Neurometry services through your NHS GP or private medical professional, recordings of consultations may be shared with your GP practice.
What personal information about me does Neurometry use?
We use the following personal information:
This includes the information that you provide us with when you register and other profile information
This includes:
This is information like your date of birth, nationality, gender, marital status and dependants
This includes:
Health tracking programmes allow you to combine data from multiple apps or devices. By doing so, you can track your health and fitness activities against your goals to provide you with a comprehensive view of your health and fitness.
This information can include all of the information listed below in examples of data from smart devices and health apps. Information may be combined from several sources to provide you with a more personalised view of your health and lifestyle.
This information can include indicators of activity such as heart rate or blood pressure, exercise summaries, nutritional intake, weight and sleep cycles.
This includes their contact details, relevant medical history if required and emergency contact information.
This includes referrals, prescriptions and fit notes
This includes:
This includes your IP address, any unique device identifiers placed by us or our service providers, the unique identifier assigned by Neurometry to your computer, mobile phone or tablet
This includes full uniform resource locators (URL); clickstream to, through and from the App and 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); methods used to browse away from the page
This may include demographic information, such as where you live and your income, if you choose to provide it. It may also include your opinions about our services. We anonymise this information before we use it to improve our services.
You can control your settings in your communications preference centre. You can find your communication preferences within the App or website under ‘Your Account’. From here you can choose the communications you would like to receive from us. You can switch these on or off any time you like.
And if you receive Neurometry services through your NHS GP or private medial healthcare professional
And if you receive Neurometry services as a benefit through a third party
Who does Neurometry share my personal information with?
To provide you with Neurometry services we need to share your personal information with the medical professionals who utilise the App as well as the Neurometry team. More detail here
The medical professionals who utilise Neurometry and its App work do so under licence. They are entirely independent of Neurometry.
The medical professionals who utilise Neurometry are responsible for maintaining the privacy of your personal information. All professionals utilising our App must have demonstrated they have completed training in personal information handling before they can start consulting with you.
We employ a clinical team, who are part of Neurometry. They may need to access your personal information so that we can provide you with services, for example if you have a query or concern about your consultation or treatment, or if the information is needed to assist our Chief Medical Officer with quality assurance. Only those employees of Neurometry who need access to information in order to do their jobs are allowed access.
We also need to share information with partner organisations that help administer Neurometry accounts.
For example:
We have vetted these organisations to ensure that they will deal with your personal information responsibly.
We do not allow these partner organisations to use your personal information for their own purposes. We only permit them to use your personal in accordance with our instructions.
We may also share information with our partner organisations who provide data analysis services, to help improve our services. This does not include information about your health.
Sometimes we need to share information with regulators like the Medicines and Healthcare Products Regulatory Agency, the Care Quality Commission, the General Medical Council, NHS England, the Information Commissioner’s Office and the Health Service Ombudsman.
With your agreement, information can be shared with relatives, partners or friends who act as a carer for you. We will only share information once the person you have asked us to share the information with has provided us with proof of their identity. We may share information with anyone you have given as an emergency contact, for example your next of kin. You can find out more by contacting us at info@neurometry.io , +442030053393 or writing to us at 71-75 SHELTON STREET, COVENT GARDEN, LONDON, WC2H 9JQ.
We may also share information with anyone else that you authorise us to e.g., your employer or your insurer.
If you are receiving Neurometry services through your third-party service provider
We will share personal data with them as this will directly impact their ability to diagnose and treat you.
There are some other rare occasions where we may share your data with other organisations.
The other organisations that we share information with depend on whether you are paying for Neurometry services or not.
If you receive Neurometry services through your NHS GP or private medical professional, then we may share your personal information with other organisations that help provide NHS or social care.
These organisations include:
If you receive Neurometry services through your NHS GP or private healthcare professional and you have agreed to receive information about our services and offers, we may share your information with marketing organisations.
For example, we may share you contact information with companies that we use to send marketing emails. Although we will not share information about your health with these organisations, it may be possible for them to infer this information due to the content of the marketing email. For example, if we are sending you information about how we can help you manage your diabetes, our partners will be able to infer that you have this condition. You can control your settings in your communication preferences.
You can find your communication preference centre within the App or website under ‘Your Account’. From here you can choose the communications you would like to receive from us. You can switch these on or off any time you like.
If you receive Neurometry services through your NHS GP or private healthcare professional and you have agreed to receive information about the products and services of third parties that may be relevant to you, we won’t share information about you with those third parties. Instead we will let you know information about them so that you can use their products or services if you wish.
If you pay for Neurometry services yourself
If you receive Neurometry services as a benefit through a third party
Our app and the website include some social media features, such as the Facebook button and the ‘Share This’ button. You can use these features to share information about your use of Neurometry through social media. The relevant social media site(s) control how these features work. If you want to find out more about this you should read the privacy policy of the relevant social media site.
Where is my data stored?
Most of the time your personal information stays within the UK or European Economic Area (EEA). Sometimes your personal information may be transferred to our partners outside of the UK or EEA with appropriate legal safeguards in place.
How long does Neurometry keep my personal information for?
Medical information
If you receive Neurometry services through your NHS GP or private medical healthcare professional, clinical information will be stored on your GP practice’s electronic patient record system. For information about how long that information is stored, please refer to your GP practice’s privacy notice. You can usually find this on their website. Information may be retained for up to 10 years.
If you pay for Neurometry services yourself or you are receiving Neurometry services as a benefit through a third party, clinical information will be stored on Neurometry systems. Information may be retained for up to 10 years.
Whether you receive Neurometry services through your NHS GP, private medical healthcare professional, or pay for Neurometry services yourself, or you are receiving Neurometry services as a benefit through a third party, records will be retained by us for up to 10 years.
Other information
Account information for individuals (including people who have completed the on-line registration process) who have not used our services will be deleted after two years, unless we are required to retain such information for any legal or regulatory reason.
Account information about individuals (for example your name, log in details, summary details of the Neurometry services you have used, any complaints you have made about our service) who have accessed our services will be kept until two years after they last accessed the services or communicated with us, whichever is later.
If you pay for Neurometry services yourself or you are receiving Neurometry services as a benefit through a third party and you have let us know through your communication preferences that you are happy to receive marketing information, we keep the information we need for marketing for a maximum of 2 years from when you last accessed the Neurometry website or app.
You can find your communication preferences within the App or website under ‘Your Account’. From here you can choose the communications you would like to receive from us. You can switch these on or off any time you like.
How does Neurometry keep my information secure?
At Neurometry we take security and the secure storage of personal data seriously. We encrypt and store all personal data on secure servers using the latest technologies which are protected by several layers of security.
We do not store any of your personal health data on your mobile device or within your web browser storage permanently. We may collect some personal data and store it temporarily on your mobile device or within your web browser storage (e.g. your post-code during the sign-up process) but this data is not kept on your device after the process for which it is being used has ended.
When using the App or website, all your personal data is transmitted through the internet using Secure Socket Layers (SSL) technology. SSL is an industry standard technology designed to prevent any third party from capturing and viewing your personal data while in transit.
Access to your account is protected with a password that you create. You are responsible for keeping this password confidential. We strongly recommend that you do not disclose your password to anyone else and Neurometry will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls, emails or text messages).
For more information on how we keep your data secure, please contact us at info@neurometry.io or contact us by telephone on +442030053393
What rights do I have over my personal information?
Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.
If you receive Neurometry services through your NHS GP or private medical healthcare professional and you want to exercise any of these rights regarding information held in your medical records, you should contact your GP practice. This is because it is your GP practice who holds those records and has control over them.
Your right of access
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which mean you may not always receive all the information we have about you. You can read more about this right here.
To access a copy of your electronic medical records or other information that Neurometry holds about you, please contact us at info@neurometry.io, +442030053393 or, if available, use our live chat feature.
Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here.
We will not usually amend medical records. This is because it is important that we have a copy of the information available at the time they are treating you. Instead, we usually add a note to your record to highlight the information you consider to be incorrect.
Your right to erasure
You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right here.
Again, we will not normally delete information from medical records. This is because it is important that we have a copy of the information available to medical professionals at the time they are treating you.
Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here.
Your right to object to processing
You have the right to object to processing if we are able to process your information because the process forms part of public tasks or is in our legitimate interests. You can read more about this right here.
Your right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about this right here.
Your right to withdraw consent
You can control whether or not your personal information is used for marketing in your communication preference centre which can be accessed under ‘my account’ within the App or website. All accounts are set up so that the user does not agree to the use of their personal information for marketing unless they opt in using the preference centre.
You have the right to withdraw your agreement to the use of your personal information for marketing at any time. You can do this by changing your settings in the preference centre. Doing this means that we cannot use your personal information in the future unless you use the preference centre to opt in again.
You are not required to pay any charge for exercising your rights.
Please contact us at info@neurometry.io if you wish to make a request, or contact us by telephone on +442030053393.
We may ask you to provide us with identification so that we can be sure that we are dealing with the right person. This is a security measure. We may also contact you to ask you to put your request into writing and/ or for further information in relation to your request to speed up our response.
We try to respond to requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In these cases, we will notify you and keep you up to date about when we expect to be able to respond.
Contact us
If you have any questions, want to exercise your rights or need further information about what we do with personal information, our Data Protection Officer can be contacted by email at info@neurometry.io.
You can find also out more about our legal obligations and your privacy rights from the Information Commissioner’s Office (“the ICO“). The ICO oversees compliance with privacy laws in the UK.
The ICO can be contacted at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
Complaints
You have the right to make a complaint at any time to the ICO if you are not happy with the way that we have dealt with your personal data or a request from you to exercise your privacy rights.
We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us at info@neurometry.io or +442030053393 in the first instance.
Updating this notice
We may update this notice from time to time. If we plan to update the policy, we will let you know through the Neurometry website or the App. When you log on to your account, we will also let you know if the notice has been updated since you last accessed Neurometry services. You should stop using our website and apps if you do not agree to any changes.
This notice was most recently updated in April 2023. To obtain an historic version of this notice please contact us at info@neurometry.co.uk or +442030053393.
Cookies
A cookie is a small text file that may be placed on your computer or Device when you visit the Platform. When you next visit the Platform, the cookie allows us to distinguish you from other users. There are two categories of cookies: (a) ‘persistent cookies’ that remain on your computer or Device until deleted manually or automatically; and (b) ‘session cookies’ which remain on your computer or Device until you close your browser, when they are automatically deleted.
The cookies Neurometry uses:
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can REFUSE cookies, by activating settings of your chosen browser(s). If you alter your browser settings to refuse cookies your access to the Platform will be restricted. You can also manage your preferences in the Cookie Settings section of our website.
In addition to the cookies, we use on this website, we also use cookies and similar technologies in some emails. These help us to understand whether you have opened an email and how you have interacted with it. We use these to improve our future email communications.
Cookies may be set when you download, open or read an email from Neurometry If you have:
If you would prefer for this not to happen, please disable automatic displaying of images, or remove us from your address book or strengthen your security settings. Alternatively, you can set your browser to restrict or reject cookies.
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