Privacy Policy

Name of Company 

Hempiphany Ltd T/A Nootro Group 

Company Number: 13266523 

Contact Details  


At Nootro Labs we take data privacy very seriously and want to make sure your experience with us is the best it can be. Nootro Labs is known as the ‘controller’ of the personal data you provide to us.  

This Privacy Policy gives you a clear view of who we are, how we collect, share, and use the personal information you provide us, how we protect your data to the highest standard and the rights and choices you have to control your personal information and protect your privacy.  

Our website uses cookies – We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. By using our website and agreeing to ICO LLC’s privacy policy, you consent to our cookies in accordance with the terms of this policy.  

Privacy Policy  

  1. What Information do we collect?  

We may collect, store, and use the following kinds of personal information:  

  1. Information about your computer and about your visits to this website and use of this website (including your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views, and website navigation). 
  1. Information that you provide to us is for the purpose of contacting Nootro Labs, this may include:  
  • Identity Data including forenames, last name, maiden name, date of birth, gender and marital status  
  • Contact Data including home address, email address and telephone numbers 
  • Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access our website.   
  • Profile and Usage Data, feedback, and survey responses, and how you use our website, products and services.  
  • Marketing and Communications Data including your preferences in receiving marketing from us.  

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with the terms of this privacy policy. 

  1. Legal basis for collecting your information.  

Chapter six of the UK GDPR (General Data Protection Regulation) requires any organisation processing personal data to have a valid legal basis for that personal data processing activity. Nootro Labs processes your personal data for the following reasons:  

  1. For the performance of a contract, we enter with you 
  1. Where necessary for the compliance with a legal obligation we are subject to 
  1. For our legitimate interests.  
  1. Consent  

All the information above is to enable us to carry our services to you, we have agreed to provide a service to you and the processing is necessary for the performance of our contract with you. This may include passing your information to third parties (see below)  

Purpose/Activity Types of data Legal basis 
To initially engage with you to discuss your requirements  Identity  Contact  Consent  
We appoint or employ individuals to conduct the tasks required of Nootro Labs. We hold information about our employees, as well as those who have applied but have been unsuccessful in the recruitment process, and those who have ceased employment.  full name. address. date of birth. telephone number. email address. CV, application form/covering letter. references. declarations. equality, diversity, and inclusion monitoring; and proof of right to work documentation (such as passport); and any other relevant information required to process an application. Performance of a contract and necessary for our legitimate interest  Contractual Obligations (Under Art 6, B, of the UK GDPR) We are required to fulfil our contractual obligations.  
Manage our client relationship with you, which will include  Maintain and update your account  Notify you of any changes  Customer reviews and surveys  Re-engagement when existing product nears expiry Identity  Contact Manufacturing agreements Profile and usage  Marketing and comms  Performance of a contract  Comply with a legal obligation Necessary for our legitimate interest 
  1. General Third-Party Data Sharing. 


Whose Data we share Third Party Reason for Data Sharing Type of Data Shared 
Employee information   Sage/Payroll cloud services  To enable us to process pay for our current employees.   Identity data Contact data  Financial data Special category data   
Employee information   HMRC  We can inform HMRC of a new starter or leaver.  Identity data Contact Data  
  1. How long we keep your data for? 

We will retain all data in line with our Records Management and Data Retention Policy.  

  1. International data Transfers. 

The information that is collected by Nootro Labs will not be transferred outside of the Kingdom.  

  1. Security of your personal information. 

We will take reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of your personal information. 

We will store all the personal information you provide on our secure (password- and firewall-protected) servers. 

All electronic transactions entered via the website will be protected by encryption technology. 

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. 

  1. Your rights as a data subject  

You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to the following conditions:  

  1. There will be no charge for the initial provision of your personal information. However, where requests from a data subject are manifestly unfounded or excessive, in terms of their repetitive character, we reserve the right to charge a reasonable fee taking into account the administrative costs of providing the information; and 
  1. The supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address). 

We may withhold such personal information to the extent permitted by law.  

  1. Under the UK GDPR you have rights in relation to your personal data. The rights available to you depend on our reason for processing your information. You have the following rights: 
  • Right to be inform – You have a right to be told how we use your personal information.  
  • Right of access – You have a right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email. 
  • Right of rectification – Under certain circumstances you have the right to rectification if you believe your data is incorrect. 
  • Right to erasure (Right to be forgotten) – Under certain circumstances, you have the right to erase your personal data. 
  • Right to restrict processing – Under certain circumstances, you have the right to object to our processing your personal data or to restrict our processing of it. 
  • Right of data portability – You have the right to have the personal data we hold on you transferred to another organisation; 
  • Right to object – Where you have given consent to any processing (including marketing) you have the right to withdraw that consent at any time (but this does not affect processing which we have done on that basis prior to you withdrawing consent). 

To exercise any of these rights please contact us at   

  1. Complaints 

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy and comply with the UK GDPR & Data Protection Act 2018. If you wish to make a complaint about how we have handled your personal data, in the first instance please contact via email on   

If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority the Information Commissioners Office

Information Commissioner’s Office 
Wycliffe House 
Water Lane 
SK9 5AF 

Helpline number: 0303 123 1113 

Get in touch

If you would like to know more about how Nootro Labs and our privacy policy, do not hestitate to get in touch