Privacy Notice

This notice explains how ELUMY LIMITED collects, uses and protects your personal information when you visit our website or contact us through it.

1. Who we are

ELUMY LIMITED (“ELUMY”, “we”, “us”, “our”) is the data controller responsible for your personal information collected through this website. We process your personal information in accordance with the UK GDPR, the Data Protection Act 2018 and, for electronic marketing and cookies, the Privacy and Electronic Communications Regulations 2003 (PECR).

• Company: ELUMY LIMITED (registered in England & Wales, company number 17123991)
• Contact for privacy matters: privacy@elumy.health

We are not currently required to appoint a Data Protection Officer. Any questions about this notice can be sent to the contact address above.

2. Information we collect

We only collect what we need. Depending on how you use the site, this may include:

Information you give us

• Early-access form: your first name (optional) and email address.

Information we collect automatically

• Campaign information: where a link you followed contains campaign tags (for example utm_source, utm_medium, utm_campaign), we receive those tags with your form submission so we understand how you found us.
• Technical information: like most websites, our hosting provider automatically records limited technical information in server logs — such as your IP address, browser and device type, and the pages you visit — to keep the site secure, available and working correctly. We do not use this information to identify you personally.

We do not collect health information, special category data, or payment details through this website.

3. How and why we use your information

Under UK data protection law we must have a lawful basis for using your information. Our uses and bases are:

Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights, and we believe they are not. You can object to this processing at any time (see Your rights).

4. Marketing

We will only send you marketing or update emails where you have asked us to (for example by joining the early-access list). Every marketing email includes an unsubscribe link, and you can opt out at any time by contacting us. Withdrawing consent does not affect anything we sent lawfully beforehand.

5. Cookies and similar technologies

Our website does not use analytics, advertising or tracking cookies, and we do not track you across other websites. We use only cookies or similar local storage that are strictly necessary for the site to work and to remember your cookie choice. Because these cookies are strictly necessary, they are exempt from the consent requirement under PECR, and we do not set any cookie that requires your consent. When you first visit, we show a short cookie notice, and you can control cookies through your browser settings at any time.

6. Who we share your information with

We do not sell your personal information. We share it only with service providers who help us run the website and respond to you, and only as needed. These may include:

• our website hosting provider, 123-Reg Limited (123-reg.co.uk);
• Microsoft, whose Microsoft 365 service we use to receive and respond to your enquiry;
• a purchaser or investor, and their professional advisers, in connection with a financing, merger, acquisition or reorganisation of our business, under appropriate confidentiality obligations;
• professional advisers, and authorities or regulators where we are legally required to disclose information.

These providers act on our instructions under contracts that require them to protect your information.

7. International transfers

We keep your personal information within the UK. Our hosting and email providers store and process your information in the UK, and we do not transfer it outside the UK. If this ever changes, we will update this notice and put appropriate safeguards in place — such as the UK International Data Transfer Agreement — before doing so.

8. How long we keep your information

• Enquiries: for as long as needed to deal with your enquiry and any resulting relationship, and for a reasonable period afterwards (up to 24 months), unless we still have a lawful reason to keep it.
• Early-access / marketing list: until you unsubscribe or ask us to remove you, or after 24 months of inactivity.

When we no longer need your information we will securely delete or anonymise it.

9. Your rights

Under UK data protection law you have the right to:

• be informed about how we use your information (this notice);
• access a copy of the information we hold about you;
• have inaccurate information corrected;
• have your information erased in certain circumstances;
• restrict or object to our processing in certain circumstances;
• data portability, where processing is based on consent or a contract and is automated;
• withdraw consent at any time, where we rely on consent.

To exercise any of these rights, contact us using the details below. We will respond within one month. Exercising your rights is free in most cases.

10. How we protect your information

We use appropriate technical and organisational measures to protect your information against loss, misuse and unauthorised access, and we require our providers to do the same. No transmission over the internet can be guaranteed as completely secure, but we work to protect your information and to respond appropriately to any suspected breach.

11. Children

This website and its forms are intended for adults and are not directed at children. We do not knowingly collect information from children through this website.

12. Changes to this notice

We may update this notice from time to time. When we do, we will change the “last updated” date at the top, and where changes are significant we will take reasonable steps to bring them to your attention.

13. How to contact us and how to complain

For any questions about this notice or to exercise your rights, contact us at privacy@elumy.health.

You also have the right to complain to the UK’s data protection regulator, the Information Commissioner’s Office (ICO). We would appreciate the chance to address your concerns first, but you can contact the ICO at any time:

• Website: ico.org.uk
• Helpline: 0303 123 1113