Privacy Policy

Introduction

Welcome to the Nebu-Flow® privacy policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy sets out how we use and protect your personal data when you visit the website www.Nebuflow.com (the Site) (regardless of where you visit it from) or otherwise interact with us (including introductions in business context, responding to marketing advertising or surveys and sharing contact information). The policy will tell you about your privacy rights and how the law protects you.

The Site is owned and operated by Acu-Flow Limited (trading as Nebu-Flow®). More details on “who we are” are set out below. This Site is not intended for children and we do not knowingly collect data relating to children.

Important information on who we are and the Site

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Acu-Flow Limited (Company number SC624449) is the controller and responsible for your personal data (collectively referred to as “Acu-Flow”, “Nebu-Flow®”, "we", "us" or "our" in this privacy policy).

We have a team who are responsible for overseeing questions relating to this privacy policy and our data protection practices. This includes our external data protection officer, MBM Commercial LLP. If you have any questions about this privacy policy or our practices, please get in touch using the details below.

Contact details

Full name of legal entity: Acu-Flow Limited, trading as Nebu-Flow®

Email address: info@nebuflow.com

Postal address: 4/3 Waterloo Chambers, 19 Waterloo Street, Glasgow, United Kingdom, G2 6AY

UK’s Information Commissioner’s Office Registration Number ZB313317

DPO Details: Data Protection, MBM Commercial LLP, Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS

DPO Email: DataProtection@mbmcommercial.co.uk

‍Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated on 22 September 2023.

Third-party links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or 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 (anonymous data).

The type of data we collect, use, store and transfer will depend on the way you interact with us and the relationship we have with you. The following kinds of personal data may be collected in different circumstances (and we have set out details of this in the table below on how we process your information):

Contact Data includes name, email address, postal address and telephone numbers.
Organisational Data includes job title, organisation or academic institution you are associated with
Transaction Data includes details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site or any newsletters we issue.
Profile Data includes your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Site, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not knowingly collect any Special Categories of Personal Data or criminal conviction information about you.

Your contact details

Please help us keep our records updated by informing us of any changes to your e-mail address and other contact details. Email info@nebuflow.com with the subject line “Change of details”.

How is your personal data collected?

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

Direct interactions. We will collect some personal data from you directly following meetings in a business context or where you provide information online via Site forms, request marketing to be sent to you, any interactions you have with us through the Site or any of our social or give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third Party and publicly available sources. We may collect some personal data about you from public sources. Additionally, Technical Data may be received from third party analytics providers or advertising networks. Please see our cookie policy for further details.

How we use your personal data

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

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party). When we process your personal information under this circumstance, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we need to comply with a legal obligation.
Where we have your consent, mainly for marketing purposes where you sign up through our Site or give us permission by email.

Additionally we will get your consent before sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us or by clicking the “unsubscribe” link provided in any communication.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

‍Purpose/Activity

To register you as a new customer

‍Type of data

(a) Contact

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

‍Purpose/Activity

To provide services to you as a customer and recover any money owed to us.

‍Type of data

(a) Contact

(b) Transaction

Lawful basis for processing including basis of legitimate interest‍

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)‍

Purpose/Activity‍

To manage our relationship with you.

‍Type of data‍

(a) Contact

(b) Profile

Lawful basis for processing including basis of legitimate interest‍

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Site, products/services to enable us to develop our relationships and grow our business)

(d) Consent – in relation to Marketing and Communications and providing updates on future surveys or workshops.

‍Purpose/Activity‍

To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

‍Type of data‍

(a) Contact

(b) Technical‍

Lawful basis for processing including basis of legitimate interest‍

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

‍Purpose/Activity‍

To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

‍Type of data
(a) Contact

(b) Profile

(d) Marketing and Communications

(e) Technical ‍

Lawful basis for processing including basis of legitimate interest‍

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

‍Purpose/Activity‍

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

‍Type of data‍

(a) Technical

(b) Usage

‍Lawful basis for processing including basis of legitimate interest‍

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

‍Purpose/Activity‍

To send marketing and advertising information to you

‍Type of data‍

(a) Contact

(b) Marketing and Communications‍

Lawful basis for processing including basis of legitimate interest‍

Consent‍

Marketing ‍

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Marketing includes where we contact you to take part in future surveys or workshops and to find out the latest news and updates about our business. We may use your Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

You will only receive marketing communications from us if you have requested that information from us and you have not opted out of receiving that marketing information.

Third-party marketing ‍

We may contact you with details of surveys or workshops run by third parties which may be of interest, but you will have the option whether or not to share your information with these third parties. We will not share your details with any third party for marketing purposes without your express consent. ‍

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 data provided to us as a result of a product/service purchase 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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see http://www.aboutcookies.org/‍

Change of purpose ‍

We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

Service providers who provide services on our behalf, like marketing, systems administration services or IT providers.
Professional advisers based within the UK who provide required professional services.
Regulatory, government and industry bodies, like ICO, HM Revenue & Customs, fraud prevention organisation or law enforcement bodies who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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

International transfers

We process the information provided by you within the UK or EEA.

Where you are based within the UK or EEA, we will let you know before we transfer your data out with these locations.

Where you are based out with the UK or EEA and provide us with information, we will transfer your personal data between your location and where we process information within the UK or EEA to enable us to process personal data in line with this policy.

If there is any other international transfer of personal data required, we will let you know before we transfer. Any such transfers would only be done where a similar degree of protection is afforded to the personal data (either by the country having an adequacy finding for personal data or an appropriate contract is in place to enable the transfer).

Data security

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted online or through the website. Any transmission is at your own risk.

Once we have received your information, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data which include.

Your right to be informed: You have the right to understand how we collect and use your data. This privacy policy is our main way of giving you this information but you can also contact us for further information if required.
Your right of access: You have the right to ask us for copies of your personal information.
Your right of rectification: You have the right to ask us to rectify information you think is inaccurate.
Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
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 our public tasks, or is in our legitimate interests.
Your right to data portability: This only applies to data 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 in talks about entering into a contract and the processing is automated.

More details on UK rights can be found at https://ico.org.uk/global/privacy-notice/your-data-protection-rights/. There may be different or additional rights that apply in your location, and for more information please contact our DPO.

If you wish to exercise any of these, please email DataProtection@mbmcommercial.com and our DPO will be able to assist.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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