Privacy Policy

Who are we?

MyCognition Limited is a private limited company incorporated in England and Wales under registered company number 07875247 with its registered office at Camburgh House, 27 New Dover Road, Canterbury, Kent CT1 3DN and is a ‘controller’ under the General Data Protection Regulation and the Data Protection Act 2018

Whose data do we hold?

We may hold data about the following people:

  • Employees
  • Customers and clients
  • Suppliers and service providers
  • Advisers, consultants and other professional experts
  • Complainants and enquirers

What data will we collect?

We will only collect information from you that is relevant to the matter that we are dealing with. In particular we may collect the following information from you which is defined as ‘personal data’:

  • Personal details
  • Family, lifestyle and social circumstances
  • Cognitive profile
  • Financial details
  • Business activities of the person whose details we are processing


For the online services that MyCognition provides (MyCognition Home, Pro and Ed, and Aquasnap), we only collect the minimum information required to provide the service. This information is:

  • Name and email
  • Age
  • Gender
  • Cognitive profile

How do we handle your data?

For the online services that MyCognition provides (MyCognition Home, Pro and Ed, and Aquasnap), all data is stored securely in ‘the cloud’ using Amazon Web Services facilities in Eire (EU). No data is stored on the app.

All data sent over the Internet (from the app to the cloud) is encrypted.

The data centre we use (Amazon Web Services) complies with ISO27001.

Special Categories

We may also collect information that is referred to as being in a ‘special category’. This could include:

  • Physical or mental health details
  • Racial or ethnic origin
  • Religious beliefs or other beliefs of a similar nature
  • Criminal convictions
  • Sexual orientation


None of this information is required or captured as a part of the online services that MyCognition provides (MyCognition Home, Pro and Ed, and Aquasnap).


Basis for processing

The basis on which we process your personal data is one or more of the following:

  • It is necessary for the performance of our contract with you
  • It is necessary for us to comply with a legal obligation
  • It is in our legitimate interests to do so
  • You have given us your consent (this can be withdrawn at any time by advising our data protection officer) either directly or through your trial manager

National Data Opt-out

Information about your health and care helps the NHS to improve your individual care, speed up diagnosis, plan your local services and research new treatments.

In May 2018, the strict rules about how this data can and cannot be used were strengthened. The NHS is committed to keeping patient information safe and always being clear about how it is used. The NHS, local authorities, university and hospital researchers, medical colleges and pharmaceutical companies researching new treatments can use your confidential patient information for research and planning. You can choose whether your confidential patient information is used for research and planning.

Type 1 Opt-out: medical records held at your GP practice

You can tell your GP practice if you do not want your confidential patient information held in your GP medical record to be used for purposes other than your individual care. This is commonly called a type 1 opt-out. This opt-out request can only be recorded by your GP. If you choose a Type 1 opt-out, you should ask your GP for a National Type 1 Data Opt-out Form.

Type 2 Opt-out: information held by NHS Digital

A Type 2 opt-out is an objection that prevents your personal confidential information from being shared outside of NHS Digital, that is used for research and planning. Previously you could tell your GP surgery if you did not want NHS Digital to share confidential patient information that is collected from across the health and care service for purposes other than your individual care. This was called a type 2 opt-out. From 25 May 2018 the type 2 opt-out has been replaced by the national data opt-out. Type 2 opt-outs that have been recorded previously have been automatically converted to national data opt-outs. You do not need to do anything if you are happy about how your confidential patient information is used. If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service. You can change your choice at any time. To find out more or to make your choice visit and/or view the NHS Digital patient Leaflet.

MyCognition Ltd expects its relevant Data controllers (Trusts, GP’s etc), whether solely or jointly with another organisation, to be responsible for ensuring that national data opt-outs are applied in line with the policy. In some cases, this requires the Controller to instruct MyCognition Ltd (acting as a data processor under their instruction) to apply the national data opt-out. In line with wider legal requirements as a data processor (MyCognition Ltd) will comply with written instructions from the data controller in relation to the national data opt-out.

How will we use your data?

We may use your information for the following purposes:

  • Delivery and provision of our cognitive fitness programmes
  • Promotion of our goods and services
  • Provision of education and training to customers and clients
  • Maintaining accounts and records
  • Supporting and managing staff

In addition, we will use anonymised data (data without any personally identifiable information) created via the MyCognition services (MyCognition Home, Pro and Ed, and Aquasnap) to continually enhance the statistical accuracy of our measures and the efficacy of our cognitive intervention.


Who will we share your Information with?

Under our Code of Conduct there are very strict rules about who we can share your information with and this will normally be limited to other people who will assist with the delivery of your cognitive fitness and training programme. This may include:

  • Healthcare professionals
  • Training partners
  • Teachers (in the case of the use of MyCognition in a school setting)
  • Clinical trial managers

In each case, the data will only be shared once you or your legal representative (in the case of minors) has provided explicit consent to do so.

Where you authorise us we may also disclose your information to your family, associates or representatives and we may also disclose your information to debt collection agencies if you do not pay our invoices.


How long will we keep your information for?

  • We will normally keep your information throughout the period of time that we do work for you and afterwards for a period of six years as we are required to do by law and also by the regulations that apply to us.
  • In some cases (for example where we have prepared a will for you) we may retain your information for a longer period and we will advise you of this at the time
  • More information is set out in our data retention policy which is available on request from the data protection officer


Transfers to third countries



  • We may from time to time transfer your personal data to a country outside of the EEA.
  • Normally this will be necessary for the performance of your contract with us
  • Sometimes we may transfer for other reasons and we will ensure that appropriate safeguards are in place at all times

For the online services that MyCognition provides (MyCognition Home, Pro and Ed, and Aquasnap), we will never transfer your personal data to a country outside of the EEA.

Security arrangements

  • We shall ensure that all the information that you provide to us is kept secure using appropriate technical and organisational measures.
  • In the event of a personal data breach we have in place procedures to ensure that the effects of such a breach are minimised and shall liaise with the ICO and with you as appropriate.
  • More information is available from the data protection officer.


What rights do you have?

You have the following rights under the GDPR:

  • Right to be informed
  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to data portability
  • Right to object
  • Rights concerning automated decision-making and profiling


Right of access

  • You have a right to see the information we hold about you
  • To access this, you need to provide a request in writing to our data protection officer, together with proof of identity
  • We will usually process your request free of charge and within 30 days however we reserve the right to charge a reasonable administration fee and to extend the period of time by a further two months if the request is manifestly unfounded or vexatious and/or is very complex
  • Full details are available in our data subject access policy which is available on request from the data protection officer


Right to erasure

  • You have a right to ask us to erase your personal data in certain cases (details may be found in Article 17 of the GDPR).
  • We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by law or regulation, or that is required to exercise or defend claims.
  • To exercise your right to erasure please contact our data protection officer, Jeremy Holland, via

Who can you complain to or communicate with?

  • If you are unhappy about how we are using your information or how we have responded to your request, then initially you should contact the data protection officer, Jeremy Holland.
  • All communication to the data protection officer ( will be responded to within one working week of receipt.
  • If your complaint remains unresolved then you can contact the Information Commissioner’s Office, details available at


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