Privacy Notice

1. Purpose and status

1.1This notice explains how Cerebera processes your personal data when you use Cerebera Build, as the controller of that data.

2. Scope

2.1This document applies to CEREBERA SYSTEMS LTD, the Cerebera Build platform, related applications, APIs, integrations, personnel, contractors, suppliers and relevant customer-facing activities unless stated otherwise.

3. Who we are

3.1CEREBERA SYSTEMS LTD, company number 13522872, 167-169 Great Portland Street, London, England, W1W 5PF. Privacy contact: support@cerebera.com.

3.2Unlike our enterprise product Cerebera Advance, where the business customer is generally controller of workforce data, Cerebera Build is used directly by you as an individual founder. Cerebera is the controller of your personal data and your business data processed through the Service.

3.3If you invite a co-founder or team member to your account, each of you is a user of the Service and Cerebera remains controller of the personal data processed; you are each responsible for having a lawful basis to share the other's contact details with us.

4. Personal data we may process

4.1Identity and contact data; account and authentication data; the business information you give CB (company name, structure, directors, sector, planned activities); device, IP and diagnostic data; the customers, suppliers and contacts you add to the platform; invoices, payment status and billing data; documents you upload or that CB drafts for you; scheduling and reminder dates; your conversation history and other AI inputs and outputs; support interactions; audit and security logs.

5. Purposes and lawful bases

5.1Provide and administer the Service, including CB's drafts, comparisons and proposed actions - contract.

5.2Security, fraud prevention and service integrity - legitimate interests and legal obligation.

5.3Billing and financial records - contract and legal obligation.

5.4Support and service communications - contract and legitimate interests.

5.5Marketing (for example, product updates, partner offers) - legitimate interests or consent where required; you can opt out at any time.

5.6Improving Cerebera Build (for example, understanding which features are used) - legitimate interests, using aggregated or de-identified data where possible.

6. Device, analytics and advertising data

6.1We and our analytics and advertising providers may collect device, browser and usage data through cookies and similar technologies - see our Cookie Policy for detail and your choices.

6.2Camera, microphone, storage and notification access on mobile depend on device permissions and are only used for features you actively choose to use.

7. AI processing

7.1AI functions in Cerebera Build (drafting, comparisons, suggestions) are powered by third-party AI model providers acting as our subprocessors.

7.2AI outputs are not guaranteed accurate and require your review - see the AI features clause in our Terms of Service.

7.3We will identify material AI subprocessors in our Subprocessor List and will not use your data to train a general-purpose model unless we expressly agree this with you.

8. Sharing and subprocessors

8.1We share data with approved hosting, authentication, AI, analytics, payment (for example, our payment processor), email and support providers, professional advisers, and regulators, under appropriate safeguards.

8.2The current subprocessor list identifies each provider, its purpose, country and transfer mechanism, and is available on request.

9. International transfers

9.1Cerebera Build operates in the UK and India. Where personal data is transferred outside the UK/EEA or India, we use adequacy regulations, the UK IDTA/Addendum, EU SCCs, or another lawful safeguard as applicable.

10. Retention

10.1Retention depends on your account status and our contractual, security and legal purposes. Specific periods are set out in our Data Retention and Secure Deletion Policy.

11. Your rights

11.1Depending on applicable law, you may have rights to access, correct, erase, restrict or object to processing, request portability, withdraw consent, and rights relating to significant automated decisions. Contact us using the details in clause 3 to exercise these rights.

12. Complaints

12.1You can contact us directly with any concern. UK users may also complain to the Information Commissioner's Office; users in India may raise a complaint with the relevant data protection authority once established under applicable law.

13. Children

13.1Cerebera Build is not directed to children and is only available to users aged 18 or over, consistent with our Terms of Service.

14. Governance and review

14.1Document owner: Jay Islam. Approved by: Ritchie Nanda. Review frequency: at least annually and following material legal, technical or operational change.