Privacy Policy 

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BACKGROUND:

Cerebriam Studio Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website: www.web.cerebriam.com and www.cerebriam.com/blog (Our Site), and web application (Platform): www.cerebriam.com (collectively ‘Our Studio’) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

This policy sets out the basis on which any personal data about you will be processed and applies to the processing of personal data in connection with our software-as-a-service video editing Platform, and Our Site which contains informational material; and our direct marketing activities. The most up-to-date version of our Privacy Policy can be found at: https://cerebriam.com/privacy-policy

You agree that any use by you of the Studio shall constitute your acceptance of Our Privacy Policy and our Terms and Conditions of Use. Our Privacy Policy  sets out the terms on which we process any personal data we collect from you, or that you provide to us, while Our Terms of Use, set out the terms of use governing your use of the Studio. It is recommended that you print a copy of the Privacy Policy and Terms of Use for your future reference. If you do not agree with our Privacy Policy and Terms of Use, please refrain from using the Studio.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

“Account”	means an account required to access and/or use certain areas and features of Our Platform;
“Cookie”	means a small text file placed on your computer or device by Our Studio when you visit certain parts of Our Studio and/or when you use certain features of Our Platform. Details of the Cookies used by Our Studio are set out in Part 12, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About the Date Controller

Our Studio is owned and operated by Cerebriam Studio Ltd. We are a limited company registered in England and Wales under company number 11298954. Our registered address is 20-22 Wenlock Road, London, N1 7GU, UK.

For the purposes of data protection legislation in the European Union:

• the data controller (i.e. the person that determines the purposes and manner in which your personal data are processed) is Cerebriam Studio Ltd, in connection with: (i) Identity Data; (ii) Contact Data; (iii) Transaction Data; (iv) Technical Data; (v) Profile Data; and (vi) Usage Data
• the data controller in connection with the Content Data is the Platform account holder. Cerebriam Studio Ltd is the data processor and merely processes personal data in accordance with the instructions given to us by the account holder

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Studio. Our Studio may contain links to other platforms and websites. Please note that we have no control over how your data is collected, stored, or used by other platforms and we advise you to check the privacy policies of any such platforms before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 13.

b) The right to access the personal data we hold about you. Part 11 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 13 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we Please contact us using the details in Part 13 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, you have the right to request that we provide you with a copy of all of it, and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically and economically feasible for us to do so

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

j) For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

k) It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

l) Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

m) If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

5.1 Personal information we may process about you

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

• Identity Data, which includes your first name, last name, social media profile, user ID, company name, job position and company department.
• Contact Data, which includes your email address and postal address.
• Content Data, any personal data which is contained within the, video, audio, or image files you uploaded to Our Platform for editing 
• Transaction Data, which includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data, which includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location you use to access the Platform.
• Profile Data, which includes your password, subscriptions purchased by you, your preferences, feedback and survey responses.
• Usage Data, which includes information about how you use our Studio

6. Data Do You Collect and How?

Depending upon your use of Our Studio, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table.

We also collect, use and share aggregated data such as statistical or demographic data for our business purposes. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Platform 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 collect any special categories of personal data 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). Nor do we collect any information about criminal convictions and offenses.

The Company is the developer of Cerebriam Studio, a proprietary software product (the “Cerebriam  Software”)  which uses AI to automate certain video production techniques requiring only minimal user input, thereby simplifying the technical process of video production, improving the quality and speed of video production, and reducing the cost of the production. Our Studio operates to both market to individuals and organisation Cerebriam Software; as well as make Cerebriam Software available for use and purchase.  To the extent we collect personal data via the Our Studio, our main purpose is to better serve our current and potential customers and to improve the function of Our Studio. A breakdown of the personal data we may process is set out in the table below.

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how long we may keep your personal data, how we may use your personal data, and Our lawful bases for doing so:

Type of data	Why it’s processed?	Legal basis for processing	Period data is stored	Will data be shared with third parties?	Will data be transferred outside EEA
Technical Data – The IP address or other unique identifier of the device you used to access our Studio.	To improve the function of the Studio.	Processing is necessary for our legitimate interests (i.e. to understand who is visiting the Studio).	3 years	For analytics and error tracking purposes, may share this data with organizations such as Amplitude, Inc., Twitter Inc., Microsoft Corp., Google LLC and Facebook Inc. or their or its affiliates. This helps us improve our Studio.	Amplitude, Inc., Twitter Inc., Microsoft Corp., Google LLC and Facebook Inc. or their or its affiliates may store and process this data in the USA. To ensure these transfers are lawful, we rely on the fact that each entity is certified as complying with the EU-US Privacy Shield regime. In the event they are not certified by the EU-US Privacy Shield regime, we will ensure another lawful mechanism exists.
Technical Data and Usage Data	To improve the function of the Studio	Processing is necessary for our legitimate interests (i.e. to understand who is visiting the Studio).	3 years	We may share this data with organizations such as Amplitude, Inc. for analytics and error tracking purposes. This helps us improve our Platform.	Amplitude, Inc.. stores and processes this data in the USA. To ensure this transfer is lawful, we rely on the fact that Amplitude, Inc. is certified as compliant with SOC type 2, ISO 27001 EU Privacy Shield, and GDPR
Identity Data	To enable us to engage in direct marketing (such as newsletters or marketing emails for products and services provided by us that we believe will be of interest to you).	Processing is necessary for our legitimate interests (i.e. direct marketing activities to customers and potential customers).	Until such time as you inform us you don’t want to continue receiving marketing communications – you have the right to unsubscribe at any time.	We use third party CRM or analytics providers such as HubSpot Inc. to manage our sales and marketing activities.	HubSpot Inc. stores and processes personal information in the USA. To ensure this transfer is lawful, we rely on the fact that HubSpot Inc. is certified as complying with the EU-US Privacy Shield regime.
Contact Data	Records of your communication with us may be used to enable us to maintain records with our potential and actual clients.	Processing is necessary to take steps at your request prior to entering into a contract. If this doesn’t apply, then you have provided your consent.	For up to 6 years	We may use third party hosted services such as Google to manage our activities.	We may use hosted services (such as Google) which stores and processes personal information in the USA or elsewhere. Where we do so, we will ensure that the transfer is lawful.
Identity Data, Contact Data, Technical Data and Profile Data.	We may use any personal data you provide to us as part of any survey to improve Our Studio or services.	Processing is necessary for our legitimate interests (i.e. to understand the requirements of our potential and actual clients).	For as long as we are using such data to improve our services and for a reasonable period afterwards.	We may use third party hosted services such as Google to manage our activities.	We may use hosted services (such as Google) which stores and processes personal information in the USA or elsewhere. Where we do so, we will ensure that the transfer is lawful.
Identity Data, Contact Data and Profile Data.	To register you as a new customer.	Performance of a contract with you.	Until such time as you delete your account.	We share this data with organizations such as Atlas (t/a MongoDb Inc.), to help store user account information.	Atlas stores this data in the USA. To ensure this transfer is lawful, we rely on the fact that we have a contract in place with Atlas (i.e. the Standard Contractual Clauses) which is approved by the European Commission and gives personal data the same protection it has in Europe.
Identity Data, Contact Data and Profile Data.	To process users’ access to the Studio, including ensuring secure access to the Studio	Performance of a contract with you. Necessary to comply with a legal obligation.	Until such time as you delete your account.	We share this data with organizations such as Auth0, Inc., to ensure secure access to the Studio.	Amazon Web Services Inc. stores this data in the EU and is certified as complying with GDPR.
Identity Data, Contact Data and Transaction Data.	To manage payments, fees / charges and to collect / recover money owed to us.	Performance of a contract with you. Processing is necessary for our legitimate interests (i.e. to recover debts due to us).	For as long as debts remain outstanding.	We will share your email address with Stripe Inc. so that payment receipts can be sent to you by email.	Stripe Inc. stores this data in the USA. To ensure this transfer is lawful, we rely on the fact that Stripe Inc. is certified as complying with the EU-US Privacy Shield regime.
Content Data.	To edit, video, audio, image, and other multimedia files together.	Performance of a contract with you. Necessary to comply with a legal obligation.	Until such time as you delete the multimedia or your account.	To help us store multimedia, we share this data with organisations such as Atlas (t/a MongoDb Inc.), Amazon Web Services, Inc. or its affiliates.	Atlas, Amazon Web Services, Inc. or its affiliates store this data in the USA. To ensure this transfer is lawful, we rely on the fact that we have contracts in place (i.e. the Standard Contractual Clauses) which is approved by the European Commission and gives personal data the same protection it has in Europe.
Identity Data, Contact Data, and Profile Data.	To manage our relationship with users which will include notifying users about changes to our terms or privacy policy.	Performance of a contract with you. Necessary to comply with a legal obligation.	Until such time as you delete your account.	We may use third party CRM providers such as HubSpot Inc. to manage our sales and marketing activities.	HubSpot Inc. stores this data in the USA. To ensure this transfer is lawful, we rely on the fact that HubSpot Inc. is certified as complying with the EU-US Privacy Shield regime.
Identity Data, Contact Data and Technical Data.	To administer and protect our business and the Studio (e.g. making users aware of new features or system issues, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Necessary for our legitimate interests (i.e. 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). Necessary to comply with a legal obligation.	Until such time as you delete your account and a reasonable period thereafter.	We may share this data with organisations such as:Functional Software, Inc. (t/a Sentry) to help identify web application crashes that affect a given user; and Amplitude Inc. to provide user behaviour tracking and in-app messaging.LogRocket, Inc. to provide user session debugging	Functional Software, Inc. (t/a Sentry) and Amplitude Inc. may store this data in the USA. To ensure this transfer is lawful, we rely on the fact that Functional Software, Inc. (t/a Sentry) and Amplitude Inc. are certified as complying with the EU-US Privacy Shield regime.Trint has executed a GDPR-compliant DPA with LogRocket, Inc.
Technical Data and Usage Data	To use data analytics to improve Studio services, customer relationships, and experiences.	Necessary for our legitimate interests (i.e. to define types of customers for our services, to keep Our Studio updated and relevant, to develop our business and to inform our marketing strategy).	As there is an annual seasonality in our business, we will retain data for analytics purposes for 3 years.	We may share this data with organizations such as Functional Software, Inc. (t/a Sentry) and Amplitude Inc. for analytics and error tracking purposes. This helps us improve our Studio.	Functional Software, Inc. (t/a Sentry) and Amplitude Inc. may store this data in the USA. To ensure this transfer is lawful, we rely on the fact that Functional Software, Inc. (t/a Sentry) and Amplitude Inc. are certified as complying with the EU-US Privacy Shield regime.

Where we send electronic marketing communications we will provide an option to unsubscribe or opt-out of further communication, or you may opt out by contacting us at info@cerebriam.co.uk

We will not sell your personal data (or any other data you provide us with) to third-parties for marketing purposes.

How personal data is collected

We may obtain personal data about you in two main ways:

Direct interactions.

• You may, for example, provide us with your personal data by filling in forms on our Platform, by corresponding with us by post, phone, email or otherwise, or by providing us with your business card at an event.

Automated technologies.

• Personal data may be collected automatically (such as the automatic recognition of your IP address or placement of cookies on your device).

8. How and Where Do You Store or Transfer My Personal Data?

The personal data that we collect from you is likely to be transferred to and stored at a destination outside of the European Economic Area (“EEA”). This data may also be processed by staff operating outside of the EEA who work for us or for one of our business partners or service providers. Further information is provided in the table above.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

Purpose of sharing data and third party(s) to which data might be shared	Use justification
If you request we do so	You have provided your consent
If Cerebriam Studio Limited or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets.	Legitimate interests (i.e. to dispose of our business).
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Cerebriam Studio Limited, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.	Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person.
We may disclose your personal information to third parties, the courts and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where we are compelled or believe it is reasonable to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.	Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person. Alternatively, legitimate interests (i.e. to cooperate with law enforcement and regulatory authorities).

10. Can I Withhold Information?

You may access certain areas of Our Studio without providing any personal data at all. However, to use all features and functions available on Our Studio you are required to submit or allow for the collection of certain data.

11. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email shown in Part 13.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.

12. How Do You Use Cookies?

Our Studio may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Studio and to provide and improve Our services.

By using Our Platform, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by Platforms, services, and/or parties other than us. Third-party Cookies are used on Our Studio to improve your experience of Our Studio and to provide and improve Our services. For more details, please refer to the table below.

All Cookies used by and on Our Studio are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Studio may not function fully or as intended.

Certain features of Our Studio depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Studio may not work properly if you do so.

The following first-party, and essential, Cookies may be placed on your computer or device:

Name of Cookie	Purpose		Duration
moove_gdpr_popup	Remembers a user’s cookie preference & consent given or withdrawn for the current website.		1 year
__stripe_mid		This cookie is set by Stripe payment gateway. This cookie is used to enable payment on the website without storing any payment information on a server.	11 months
__stripe_sid		This cookie is set by Stripe payment gateway. This cookie is used to enable payment on the website without storing any payment information on a server.	30 mins

and the following third-party Cookies may be placed on your computer or device:

Name of Cookie	Provider	Purpose	Type	Duration
tk_or	JetPack	This is a referral cookie used for analysing referrer behaviour for Jetpack	Performance	4 years
tk_r3d	JetPack	Used for the internal metrics of user activities to improve user experience	Performance	3 days
tk_lr	JetPack	This is a referral cookie used for analysing referrer behaviour for Jetpack	Performance	1 year
VISITOR_INFO1 _LIVE	YouTube	Used to track the information of the embedded YouTube videos on a website.	Advertisement	5 months
YSC	YouTube	Used to track the views of embedded videos.	Performance
_ga	Google Analytics	Used to calculate statistical data on how the visitor uses the website. The cookie stores information anonymously and assign a randomly generated number to identify unique visitors.	Analytics	2 years
_gid	Google Analytics	Used to calculate statistical data on how the visitor uses the website. The cookie stores information anonymously and assign a randomly generated number to identify unique visitors.	Analytics	1 day
_gat_gtag_UA_ 175559667_1	Google Analytics	Used to distinguish users.	Analytics	1 minute
_fbp	Facebook	Used to show relevant advertisements to the users and measure and improve the advertisements.	Advertisement	2 months
Fr	Facebook	Targeted advertisements, including tracking user across websites that have Facebook pixel.	Advertisement	2 months
IDE	Google DoubleClick	Used by Google DoubleClick and stores information about how the user uses the website and any other advertisement before visiting the website. This is used to present users with ads that are relevant to them according to the user profile.	Advertisement	1 year
wc_cart_hash_# wc_fragments_#	WooCommerce	Remembers what’s in your shopping cart	Payment	Session
Lang	LinkedIn	This cookie is used to set default locale/language	Performance	Session
UserMatchHistory	LinkedIn	This cookie is used by LinkedIn Ads to help  ID syncing	Advertisement	30 days

Our Studio also uses local storage to store information locally on your computer or mobile device. Our Studio uses local storage to save multimedia to avoid loss if the Studio  closes unexpectedly, to speed up the delivery of some services, and to allow the Studio to continue providing some services without an internet connection.  

13. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please e-mail us at info [at] cerebriam.co.uk

14. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Studio and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Studio following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 1^st May 2020