Privacy Policy

Who we are?

Apoha Limited, a company incorporated and registered in England and Wales with company number 13344316 and registered office at NW Works Units 8 & 9, 135 Salusbury Rd, London, United Kingdom, NW6 6RJ (“Apoha”), is deep-science start-up that is pioneering the field of sensory intelligence. Our proprietary technology, the “Liquid Brain”, is based on foundational scientific discoveries mimicking the signal processing capabilities of neurons and artificial nano-films. This technology is the basis of our unique capability to generate multidimensional biophysical / sensory profiles for molecules and complex mixtures, with unparalleled speed and efficiency.

Our mission is to democratise material programming, making it accessible, intuitive, and effortless for everyone. Our goal is to build a future where sensory intelligence transforms technology from a mere tool into a true extension of our senses, enabling us to interact with the world in new and exciting ways. For the purpose of applicable data protection laws, we are the data controller. Our representative in the United Kingdom (“UK”) is Apoha Limited.

Our commitments

Apoha is committed to conducting its businesses in accordance with all applicable Data Protection laws and regulations in line with the highest standards of ethical conduct. This privacy policy (this “Policy”) sets forth the expected behaviours of Apoha practices in relation to the collection, use, retention, transfer, disclosure, and destruction of Personal Data belonging to all Apoha contacts (i.e. the “Data Subjects”).

Apoha strives to ensure continued and eﬀective implementation of this Policy and expects all stakeholders to share this commitment. This Policy (together with our “Terms” of use and any other document referred to on it) sets out the basis on which any personal data (as defined in Regulation (EU) 2016/679 (the “GDPR”)) that we hold (the “Personal Data”) are processed.

Please read the following carefully to understand our views and practices regarding your Personal Data and how it’s processed. If you have any concerns or need further information, our team can be contacted directly with the details below:

‍Apoha Limited
‍NW Works Units 8 & 9, 135 Salusbury Rd.

London, United Kingdom, NW6 6RJ

Phone: +44 7770 449958
Email: shamit@apoha.ai

Your personal data

We may collect and process some or all of the following types of Personal Data:

Names, Home address, Email address, Phone number, Date of birth, NI / SS Number, Passport Number, Bank Account details, Other Credit Information (where necessary). These can be obtained from Job Agencies, Internal referral, Online, Onsite visitors’ registration system, Direct email messages, Direct phone calls.
Pseudonymised data sets, Pseudonymised patient level data and Human tissues and blood samples obtained from Data banks/Suppliers, Collaborators/Institutions and CROs.
Supplier/Vendor/Contact ID, Email address, Company Physical Addresses, Company Contact Information, Name, Home Addresses, Phone number, Financial Information and Bank account information obtained from Onsite visits, Direct email messages and Phone calls.

Technical information we may collect
‍

Internet Browsing

Activity data, such as when you completed a form on this website

Information from your visits to this website, including the type of browser and operating system you use,

Access times, pages viewed, URLs clicked on, your IP address and the pages you visited

Tracking pixels that allow platforms such as Facebook and Twitter to interact with this website and give feedback on your actions; and

Device information, including the unique device identifier, hardware model, operating system and version and mobile network information

We use this information to create and maintain your account, to send you email newsletters as per your subscription request, to communicate with you, provide customer support and to address and remediate technical issues and bugs.

This is necessary to perform our contract with you to provide services. We use this information with your consent and it is in our legitimate interest to provide effective services to you and to be responsive to you.

Information we may collect from other parties

We may source data from providers from time to time which may be combined with information you give to us and information we collect about you. We may use this information and the combined data for the purposes set out in this Policy (depending on the types of data we have received).

‍Pseudonymised Datasets
‍We may collect pseudonymised datasets from data suppliers, CROs and collaborators for internal research purposes.

‍Clinical Trial Data
‍We may work with vetted CROs and test centres from time to time who provide participant’s pseudonymised data for use in our research. From time to time, these processing may involve special category personal health data. Apoha Limited will rely on the exception under Articles 9(2)(i) and 9(2)(j); and Article 89(1) of the GDPR (Legitimate Interests, Scientiﬁc or Historical Research Purposes) and Schedule(1), Part (1) sections 10 and 19 of the Data Protection Act 2018 (“DPA 2018”) as our lawful basis for processing.

Newsletter subscribers

When you subscribe to Apoha’s newsletter, we will ask for your:

Names

Email address, and

Any other content preferences that can help tailor our messages to your interests

Our use and storage of your data is based on your consent. This means you will receive tailored communication and updates regarding our upcoming events, products, services or opportunities from time to time. You can withdraw your consent or change your preference at any time, by following the ‘Unsubscribe'  link on any of our emails or contacting us at the contact mentioned at the end of the document. When you unsubscribe, your personal data will be automatically removed from the newsletter distribution system.

Event attendees 

When you register to attend one of our events (including via any of our third-party provider), we will ask for your:

Names

Email address, and

Any other relevant information as determined on an event-by-event basis; such as, job title or work-related email address.

We will collect this information when you enroll to attend an event. Our use and storage of these data is based on your consent. We use the data solely for the purposes of administering the event and send you tailored communication and updates regarding our upcoming events, products, services or opportunities from time to time. We may be required to share such data with third-party organisations where necessary to administer the event eﬀectively.

We often take photographs at our events and those photos may be used on our website, social media, newsletters or other internal or external communications. Please contact us if you have any question or concern regarding the use of such photographs at any time. If you are a speaker at one of our events, we may promote your participation via platforms such as Twitter, LinkedIn and by marketing emails. External platforms may continue to store and use personal information after the event has ended.

How we process personal data

We rely on Contractual Performance, Public Interest, Legitimate Interest, and Legal Obligation (each as defined in the GDPR) as the lawful basis on which we collect and use your Personal Data. We use your Personal Data to provide you with information about our products, and services and to improve those products and services. We will also use your Personal Data to notify you about changes and events and to ensure that content on our website is presented in the most eﬀective manner for you and your computer.

How the company shares your information

All the Personal Data we collect from you are used for administrative (HR) and research purposes. If there is a need to disclose your Personal Data to other third parties, for new purposes outside the original scope or for purposes materially diﬀerent from that for which they were originally collected, we will ensure that your rights and freedom are not undermined. Where applicable, we will give you the opportunity to decide if your Personal Data should be processed in such a manner. However, note that in certain circumstances, we might be required to disclose your data in response to lawful requests by public authorities, to meet national security, law enforcement, or investigations and we will oblige accordingly.

Where we store your information

Apoha Limited and its aﬃliated/trusted third-party suppliers may store your Personal Data within and outside the EEA and the UK. Data protection and privacy laws in the countries to which your Personal Data are transferred may be deemed inadequate under the GDPR. In all cases, Apoha Limited takes all steps reasonably necessary to ensure your Personal Data remains protected and secure in compliance with applicable data protection and privacy laws. These measures include data transfer agreements, implementing standard contractual clauses, or International Data Transfer Agreements (“IDTAs”).

Security

We take appropriate technical, organisational, and administrative measures to ensure all Personal Data is kept secure including security measures to prevent Personal Data from being accidentally collected, recorded, organised, structured, stored, altered, retrieved, consulted, used, disclosed by transmission, disseminated or otherwise made available, aligned or combined, restricted, erased or destroyed in an unauthorised manner. We limit access to your Personal Data to those who have genuine business needs and are duly trained for such processing. Those processing your information will do so only in an authorised manner that ensures conﬁdentiality and accountability. We also have procedures in place to deal with any suspected data security breach. We will notify you and all applicable regulators of a suspected data security breach where we are legally required to do so within 72 hours.

Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means outside the scope of this Policy, therefore any such transmission remains at your own risk as the transmission of information via the internet is not completely secure.

How long we retain your Personal Data

We will retain your Personal Data as follows:

(a) your account data for as long as you keep your account open or as needed to provide you with our products or services;
(b) if you contact us, we will keep your data for 24 months after you contact us; 
(c) your technical usage information may be retained for up to 24 months; and
(d) data on your use of our website and our products or services maybe retained for up to 24 months.

We will also retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. If you stop using our products or services, we will store your information in an aggregated and anonymised format; we may use this information indefinitely without further notice to you. 

For further information, contact our team at the contact mentioned at the end of the document

Your rights and access request

Rights relating to the processing of your Personal Data

‍The DPA 2018, the GDPR, the UK General Data Protection Regulation (“UK GDPR”) and the Privacy and Electronics Communications Regulation (“PECR”) provide you with speciﬁc rights relating to your Personal Data that Apoha holds and processes at any given time. These rights include:

(a) Right to Access (Data Subject Access Request) – You have the right to access Personal Data we hold about you, how we use it, and who we share it with.
(b) Right to be Informed (Privacy Notices)
(c) Right to Object to Processing – You have the right to object to our processing of your Personal Data
(d) Right to Rectiﬁcation – You have the right to correct any of your Personal Data we hold that is inaccurate.
(e) Right to Erasure (Right to be Forgotten) – In certain circumstance, you have the right to delete the Personal Data we hold about you.
(f) Right to Restrict Processing – You have the right to require us to stop processing the Personal Data we hold about you, other than for storage purposes, in certain circumstances.
(g) Right to Data Portability – You have the right to receive a copy of the Personal Data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your Personal Data. You have the right to object to marketing at any time by clicking the ‘Unsubscribe’ link on any of our emails or contacting us at the contact mentioned at the end of the document.

‍Data Subject Access Request You can request access to the Personal Data we hold about you using the contact details set out below. Requests should include:

(a) Your full name, address and description of the information that you seek.
(b) Two proof of identiﬁcation: (i) one photographic ID (a copy of your passport or driving license); and (ii) one proof of address (a recent bill or ﬁnancial statement showing your current address).

Data Subject Access Requests should be addressed to:

‍Apoha Limited
‍NW Works Units 8 & 9, 135 Salusbury Rd.

London, United Kingdom, NW6 6RJ

Phone: +44 7770 449958

We are obliged by the governing regulations to respond promptly to your request and in any event within one month of receipt. Exceptions may apply for an extended period of two months if the request proves particularly complex in nature, in which case you will be duly informed.

Should we need additional information to identify, validate and/or locate the information requested, we will contact you and wait for your response before we are able to process your request.

Onward transfers to third parties

Before any onward transfer of your Personal Data to third parties, we will ensure measures are in place that meets the level of security appropriate to such onward transfer in terms of contract (Model Clauses/IDTAs) or agreement as appropriate to ensure adequacy in line with the provision of the PDF Principles. We will ensure that any third party receiving such Personal Data from us has entered into a written agreement or contract with us requiring that such third party provide at least the same level of privacy protection as the PDF Principles.

If any third party processes Personal Data in a way that does not comply with the terms of this Policy, Apoha will take necessary steps to prevent any data breaches. We will ensure that the third-party informs us if they are unable to meet the agreed terms. The contract will clearly state that if such a situation arises, the third-party will stop processing or take appropriate steps to rectify the issue in order to comply with the PDF Principles.

Cookie policy

Read our full cookie policy -> https://app.apoha.com/docs/cookie-policy

Other website

Our website may contain links to other websites from time to time. Note that this Policy only applies to this website (www.Apoha.com and www.app.apoha.com). Whenever you are redirected or linked to other websites, ensure you read and understand their privacy policies on their use of your Personal Data before consenting. We do not accept any responsibility or liability for external policies. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of this website and/or users of those third-party online platforms without limitation as to its use by a third party or by us. Our inclusion of such links does not imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on our website. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Data by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

How to make a complaint

For concerns or questions about our privacy policy or how we process your data, contact us at:

‍Apoha Limited
‍NW Works Units 8 & 9, 135 Salusbury Rd.

London, United Kingdom, NW6 6RJ

Phone: +44 7770 449958

We believe that we can resolve any query or concern you may raise about our use of your Personal Data. The DPA 2018, the GDPR, the UK GDPR, and the PECR give you the right to lodge a complaint with a supervisory authority, in particular within the EU (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws may have occurred.

The ICO is the supervisory authority for UK and may be contacted at:
‍Online: http://ico.org.uk/concerns/ 
Telephone: 0303 123 1113.

‍Apoha keeps this Policy under regular review to continuously capture each emerging requirement. We will place any updates on this webpage.

Last updated: September 2022

At Apoha, we keep our privacy policy under regular review to continuously capture each emerging requirement. We will place any updates on this webpage.

‍Last updated: April 2022