Privacy Policy

Written By Kennedy Adamu

Last updated: 16 September 2025

1. Who we are

“The NBRH” (“we”, “us”, “our”) is the trading name of [TBC: The NBRH], registered in England and Wales under number [TBC: The NBRH]. Registered office: [TBC].
We are the data controller for the personal data described in this notice.

How to contact us: TheNBRH@gmail.co.uk

If you have appointed a Data Protection Officer or data contact, add: [kennedy_adamu@outlook.com].

2. What this policy covers

This policy explains what we collect, why we collect it, how we use and share it, how long we keep it, and the rights you have under the UK GDPR and the Data Protection Act 2018. It applies to our website, the onboarding survey, and related services.

3. The data we collect

  • Identity and contact: name, email, phone.

  • Demographics and preferences: age range, activity interests, accessibility needs, goals, preferred locations and times, responses to onboarding questions.

  • Usage and technical: pages viewed, device information, IP address, approximate location, cookies and similar technologies.

  • Communications: emails, messages, support requests, marketing preferences.

  • Optional or sensitive data: if you choose to share information that may reveal health, disability, ethnicity, religion, or sexual orientation. We do not require this, and we only process it with your explicit consent.

4. How we use your data and our lawful bases

We only use your data where the law allows, and typically under these bases:

  • To provide and improve the service: create and manage your profile, personalise recommendations, run features like session discovery and loyalty.
    Lawful basis: performance of a contract, legitimate interests in running and improving NBRH.

  • Research and analytics: understanding trends, improving usability, service planning. We use aggregated or anonymised data wherever possible.
    Lawful basis: legitimate interests. Where research uses sensitive data, we rely on your explicit consent.

  • Marketing: sending updates, news, offers and content.
    Lawful basis: consent, or legitimate interests where PECR permits for existing customers. You can opt out at any time.

  • Security, fraud prevention and legal compliance: keeping our services secure, complying with laws, responding to lawful requests.
    Lawful basis: legal obligation and legitimate interests.

You can withdraw consent at any time. This does not affect processing carried out before you withdrew it.

5. Marketing choices

We only send you direct marketing by email or SMS with your consent, or where the law allows because we have an existing customer relationship and you have not opted out. You can unsubscribe using the link in any email or by writing to TheNBRH@gmail.co.uk.

6. Cookies and similar technologies

We use cookies and similar tools to make the site work, remember preferences, measure performance and improve the service. Where required, we ask for consent. You can manage cookies in your browser.
If you maintain a separate Cookie Policy or banner, link it here: [Link to Cookie Policy].

7. Sharing your data

We do not sell your personal data. We share data with:

  • Service providers acting as processors who help us run NBRH, for example website hosting, cloud storage, analytics, communications, customer support, form processing and data automation tools. Typical categories may include platforms like website builders, email providers, analytics tools and cloud databases.

  • Professional advisers such as legal and accounting services.

  • Authorities when required by law or to protect rights and safety.

  • Business transfers if we restructure, merge or sell part of our business, in which case your data may transfer under the same protections.

We require processors to keep your data secure, use it only under our instructions, and delete it when finished.

8. International transfers

Some providers may process data outside the UK. Where this happens, we use safeguards recognised by UK law, such as UK adequacy regulations or UK International Data Transfer Agreements and Standard Contractual Clauses.

9. Data retention

We keep personal data only as long as needed for the purposes set out above:

  • Account and onboarding data: for the life of your account and for up to 24 months after inactivity, unless you ask us to delete it sooner.

  • Marketing data: until you opt out, then we keep a minimal suppression record so we do not contact you again.

  • Analytics and logs: typically 12 to 24 months, often aggregated or anonymised sooner.

  • Legal, security and dispute data: kept as required by law and to establish or defend legal claims.

10. Security

We use appropriate technical and organisational measures to protect your data, including encryption in transit, access controls, least-privilege permissions and regular reviews. No system is perfectly secure, but we work to prevent, detect and respond to incidents. If we are legally required to notify you of a breach, we will do so.

11. Your rights

Under UK GDPR you have the right to:

  • Access your data and get a copy

  • Correct inaccurate data

  • Delete your data

  • Restrict or object to certain processing

  • Data portability for data you provided to us and we process by automated means under consent or contract

  • Withdraw consent where we rely on it

  • Complain to the Information Commissioner’s Office (ICO)

We may need to verify your identity before acting. There is no fee unless a request is manifestly unfounded or excessive.

How to exercise your rights: email TheNBRH@gmail.co.uk.

ICO contact: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. ico.org.uk, 0303 123 1113.

12. Automated decision-making and profiling

We may use profiling to personalise recommendations, offers or content based on your survey responses and usage patterns. We do not make decisions that produce legal or similarly significant effects without human involvement. You can object to profiling at any time by contacting us.

13. Children’s data

Our services are intended for people [choose: 16+ or 18+]. We do not knowingly collect data from children under [chosen age]. If you believe a child has provided data, contact us and we will take appropriate action.

14. Third-party links

Our site may link to third-party websites. Those sites have their own privacy policies and we are not responsible for their practices.

15. How to delete your data or close your account

You can request deletion at any time by emailing TheNBRH@gmail.co.uk. We will respond within one month, or within the period allowed by law, and confirm once completed. We may retain limited information where required by law or to establish or defend legal claims.

16. Changes to this policy

We may update this policy from time to time. We will post the new version with a new “Last updated” date. If changes are material, we will take reasonable steps to let you know.

Kennedy Adamu
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