Privacy notice (Trial Participants)

Audio Analytic Limited (“Audio Analytic“, “we”, “us”) is committed to protecting the privacy and security of your personal information. This privacy notice (“Privacy Notice”) describes how we collect and use personal information about you in the course of our audio collection trials. “Personal Information” here means any information that we process about you that relates to you or that can be used to identify you – for example, your name, email or audio recordings associated with you. Audio Analytic is the controller of your Personal Information (this simply means we are responsible for your Personal Information.

HOW WE USE YOUR PERSONAL INFORMATION

We collect Personal Information about you, either directly from you or from a third-party source. Under data protection law we can only use your Personal Information where we have a lawful bases (justification), and this can be either “to carry out a contract with you or to take steps on your instruction prior to entering a contract with you”; “where we have a legal obligation”; where you have given us your consent”; or “where it is necessary for our legitimate interests” (this means that we have a business or commercial interests in using your Personal Information).

The table below sets out clearly how we collect and use your Personal Information and the lawful bases we rely on for using your Personal Information. Where we have said that using or keeping your Personal Information is necessary for our “Legitimate Interests”, we have carried out an assessment to ensure this is not unfair to you.

Please note that if you choose not to provide Personal Information requested by us, or refuse our use of your Personal Information, we may not be able to interact with you in a manner which you have requested, where this Personal Information is necessary or these interactions may be delayed. For example, we primarily process your Personal Information to facilitate our research trials which you have expressed an interest in and we may be unable to offer you a place on the trial if you do not provide us with a data point we need, such as your contact details.

Information We Collect From You

Personal Information we collect How we use your Personal Information and our lawful basis
Trial Participation Interest

You give us Personal Information about you when you express an interest in participating in our trials, either through our online research participation interest form or otherwise. This is generally your name, email address, city, country and contact preference.

Legitimate Interests

·        To assess your suitability to participate in our trials.

·        To contact you with future opportunities to participate in our trials.

Trial Registration and Participation

You give us Personal Information about you when you register to participate in our research projects and during the course of your participation. This is generally your name, address, email address, telephone number, type of trial selected, sessions booked, details of assigned devices if , signed release forms and any disability information you provide. Additional personal information may be required according to the nature of the research project, such as age and name of children and other family members.

Legitimate Interests

To register you and to administer your participation in our trials (including to ensure we can contact you throughout your involvement with us, book recording sessions with you, allocate an audio recording device to you and keep a record of where the audio device is installed). We may use Personal Information to ensure fairness of our systems such that they do not discriminate against certain individuals based on particular characteristics.

Legal Obligation

To comply with any legal requirements involved in the management of trial participants and making reasonable adjustments for trial participants, ensuring appropriate access provision and other adjustments as may be needed.

Audio Clips

We collect Personal Information about you when you participate in audio recordings either during recording sessions with us or through our audio recording devices installed in your premises. This is generally an audio clip, audio clip metadata associated with you or the audio recording device allocated to you and statistics on the performance of the audio recording device. This audio clip metadata may include personal information such as age, gender and name of children and other family members, according to the needs of the research project.

We also carry out audio recordings in public spaces and generate audio clips from these recordings. These public recordings are not targeted at any particular individuals. Although unlikely, it is possible that these recordings contain Personal Information.

Legitimate Interests

·        To assist in our research and help train our sound recognition and enhancement technology.

·        To differentiate your audio clip from that of other trial participants. Please note that for audio clip metadata, once collected, this data is used in an anonymized, aggregated form.

·         To ensure any requirements for your particular trial (such as that the device was live for a particular percentage of the time it was in your possession) have been met.

·        We may use Personal Information to ensure fairness of our systems such that they do not discriminate against certain individuals based on particular characteristics.

Contacting Us

You give us Personal Information about you when you contact us or otherwise interact with us, including via the contact us web forms on our website, phone, email, post or social media. This is generally information including your name, contact preference (email/phone number) and what you have contacted us about.

Legitimate Interests

To respond to your inquiries and fulfil your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request information before, during and after the trial. We may also take this information into account when improving how we interact with you and our trial processes.

Marketing Communications and Updates

You give us Personal Information about you when you register to receive marketing communications and updates from us. This is generally information including your email address and your marketing preferences (i.e. the updates you want to receive and how you want to receive these updates).

Consent

send you marketing communications via email where you have agreed to receive these communications. We will only do this in line with your marketing preferences and you can opt-out of receiving these communications at any time by selecting the unsubscribe link in any email we send you, or by contacting us.

Information We Collect From Third Parties

Personal Information we collect How we use your Personal Information and our lawful basis
Partnerships

Where we have entered into partnerships with other organisations, we may be provided with audio clips collected by these partners for the purposes of our research. Similar to our processing described above, these audio clips may be obtained from sound recording sessions or from device recordings.

Whether these audio clips contain any Personal Information will depend on the particular partner sharing these audio clips with us and what information they share with us. Where you have provided us with voice data through any of these partners, this will be your Personal Information. Please note that these partners  will usually have provided you with a privacy notice similar to this document when they collect any Personal Information from you.

Legitimate Interests

To assist in our research and help train our sound recognition and enhancement technology.

 

Internal Business Purposes

Personal Information we collect How we use your Personal Information and our lawful basis
Business Administration, Management, Planning and Training

Our processes for ensuring the proper day to day running of our business may apply to any of the above Personal Information we collect about you

Legitimate Interests

We use your Personal Information as necessary to operate our business efficiently (including business administration, management, planning and training).

Legal Claims and Compliance with Legal Obligations

Our processes for complying with our legal obligations and protecting our rights under the law may apply to any of the Personal Information we collect about you listed in this Privacy Notice.

Legitimate Interests

We use your Personal Information to effectively defend or bring claims to protect our legal rights and interests, to respond to investigations from regulators or law enforcement, and to audit our internal processes for compliance with legal and contractual requirements.

Legal Obligation

We use your Personal Information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities, and audit our internal processes for compliance with legal requirements.

Anonymisation and/or Aggregation Legitimate Interests

We may carry out anonymization and/or aggregation on any of your Personal Information provided above to ensure this information can no longer identify you and is therefore no longer Personal Information.

HOW WE SHARE YOUR PERSONAL INFORMATION

We share your Personal Information for the following purposes:

·        We share your Personal Information with trusted third parties who perform functions on our behalf such as service providers (including IT services providers, website providers, cloud providers, email distribution providers and direct marketing providers, contractors), business consultants, and professional advisors (including lawyers and accountants). These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

·        We may share your Personal Information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Audio Analytic. Our affiliates will use the Personal Information we share in a manner consistent with this Privacy Notice.

·        We share your Personal Information if we are under a duty to do so, in order to comply with (or where we reasonably believe we are under a duty to comply with) any legal obligation; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of Audio Analytic, third parties, trial participants or the public.

·        As we continue to develop our business, we may sell or purchase assets.  If another entity acquires us or merges with us your Personal Information will be disclosed to such entity.

·        We share your Personal Information where you give us express permission to do so in the course of your relationship with us from time to time.

INTERNATIONAL TRANSFERS

We are located in the United Kingdom and store your Personal Information on servers within the United Kingdom and European Union. We also use email communication service providers in the United States of America (US) and so your Personal Information (specifically contact details) is transferred to and processed in the US for these purposes. The US may have data protection laws less stringent than or otherwise different from the laws in effect in your country. Where we share your Personal Information with parties in the US or any countries not recognized as adequate for the transfer of your Personal Information, to the extent a safeguard is required under law for such transfers of your Personal Information, we have put in place the UK government approved international data transfer agreement/addendum and (for EEA transfers where applicable) the Standard Contractual Clauses approved by the EU Commission. Please contact us for further details on the safeguards in place and how to obtain a copy using the contact details below.

RETENTION OF YOUR PERSONAL INFORMATION

We generally retain your Personal Information only for as long as necessary to fulfil the purposes outlined in this Privacy Notice. This will generally be for the duration of research which involves use of your Personal Information, however, there may be situations where we retain your Personal Information for a longer or shorter period. When determining the relevant retention periods for your Personal Information, we take into account the following factors: (a) any permissions you give us with regards to your Personal Information; (b) our contractual obligations and rights in relation to the Personal Information involved; (c) our legal obligation(s) under relevant laws to retain data for a certain period of time; (d) our legitimate business and commercial interests; (e) the amount, nature and sensitivity of the Personal Information; (f) whether retention is advisable in light of our legal position (such as with regard to applicable statute of limitations, investigations, litigation, and other potential and actual disputes); and (g) any guidelines issued by relevant data protection authorities. In some circumstances we may anonymise your Personal Information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

 YOUR RIGHTS UNDER DATA PROTECTION LAW

By law, you have a number of rights (subject to certain conditions and exceptions) when it comes to your Personal Information and can exercise any of these rights by contacting us.:

You have the right to object to us processing your Personal Information where we rely on “legitimate interests” (see the “How We Use Your Personal Information” section above) as a lawful basis for processing your Personal Information or where we are processing your Personal Information for any direct marketing purposes (e.g. to send you newsletters and updates).

You also have the right to:

  • Request access to your data (commonly known as a “subject access request”). This enables you to receive a copy of the data we hold about you and to check that we are lawfully processing it.
  • Request correction of the data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your data. This enables you to ask us to delete or remove data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing (see above).
  • Request the restriction of processing of your data. This enables you to ask us to suspend the processing of data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request portability of your Personal Information. This enables you to ask us provide you or another party with any Personal Information we have obtained from you, in a structured, machine readable and reusable format.
  • Right to withdraw consent. Where you have provided your consent to the collection, processing or transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.This won’t affect anything we have used your Personal Information for before you withdrew your consent..
  • Right to Lodge a complaint with a data protection regulator. You have the right to lodge a complaint about the way we handle or process your Personal Information with a data protection regulator. In the UK, this is the Information Commissioners Office (ICO) Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Phone number: 0303 123 1113. Website: https://ico.org.uk/make-a-complaint/

CHANGES TO THIS PRIVACY NOTICE

We may periodically make changes to this Privacy Notice. We will notify you of any significant changes where we have a relationship with you and otherwise post updated versions here. We recommend that you revisit this Privacy Notice regularly.

HOW TO CONTACT US

If you wish to exercise any data subject rights or have any questions about this Privacy Notice or our information practices, please feel free to contact us by at emailing data.protection@audioanalytic.com or by writing to us at Audio Analytic, 2 Quayside, Cambridge, CB5 8AB.

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