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9th October 2009


This document sets out our policy in relation to the processing of personal data provided by customers of our web site.

Who is the data controller?

The controller of your data is Nurphy Ltd, a company registered in England and Wales, with company number 07038083 and registered office at Nurphy Ltd, 2 Chapel Court, Holly Walk, Leamington Spa, CV32 4YS.

Nurph Principles

Nurph is a tool for real-time chat on URLs.

Contacting Us

If you wish to contact us about any data we may hold about you, please use the Help section for information on contacting a representative.

Our Commitment

We are committed to protecting and respecting your privacy and using your data fairly and lawfully in accordance with the Data Protection Act 1998 and the Privacy and Electronic Communications Regulations 2003.

How do we collect your data?

We collect data from you when you fill in our registration form and other forms on our web site. We collect data through other communications with you. We collect and process data you provide when completing your account profile on our web site. We store and process data which you submit to our web site as part of your account or use of this web site.

What data do we hold?

Information you provide

We hold and process a range of information collected from you and provided in relation to your registration, including:-

  • name
  • e-mail address
  • location
  • summary information about you
  • biographical information about you that you provide
  • information you submit in using the services, including channels, conversations, messages, remarks, replies, and files you provide to others.

Generated Information

We generate, hold and process a range of other information relating to your registration, including all communications between us.

Web Site Usage

We hold data relating to your visits to our web sites, including through the use of cookies, which enable us to personalise your visit and monitor the performance of our web site.

We also collect statistical information about your computer, including where available your IP address, operating system, domain name and browser type, for system administration and to report aggregate information to our advertisers. This is information which your browser automatically provides to our servers when you visit our web pages, and is a normal part of the Internet.

What do we use your information for?

Administration and Provision of Services

We use your information to administer your registration with our web site and provide our web site service to you. This use may include keeping in contact with you, managing your account, and informing you of any changes to and news about our web site and service.

Web Site Usage

We use data about your visits to our web sites to personalise your visit and monitor and improve the performance of our web site.

Data Analysis

We use your data along with other data we hold to carry out general anonymous assessment, analysis and research in relation to our business, products, services and customers.


We may use your data where necessary to defend or establish our legal rights or where otherwise required by law or binding regulation.

Who do we disclose your data to?

Display on web site

As part of the service provided by our web site, the data you provide for your public profile will be made available to visitors to our web site including other registered users of the web site.

However, this will not include your e-mail address, postal address or any financial information, unless you permit this.


For administration purposes only and managing our business, we may disclose your data to a range of persons in connection with your registration, including to:-

  • Contractors whom we employ to host or run our web site and store our databases
  • Legal advisors, auditors and insurance companies

We will only disclose your personal data to the extent reasonably necessary.

Direct Marketing

Except where we have your consent, we will not use your personal data for direct marketing of services outside of Nurph web service.

Legal Disclosures

We co-operate with government and law enforcement agencies in common with similar web services, and we may, as required by law, pass your data to law enforcement agencies or other governmental agencies.

Where is your data held

All other data will be held at reputable hosting services, located in various countries in the world, and may be stored in more than one country, depending on the nature of the hosting services we use from time to time.

You consent to such transfer, hosting and storage.

In any event, we ensure that your data is only processed in accordance with our instructions, and whilst your data may be stored in different countries, your data is managed and used in accordance with the Data Protection Act 1998 of England and Wales.

Data Security

We are firmly committed to data security and we take steps to guard against unauthorised access to personal data.

Your rights

The Data Protection Act 1998 gives you the following rights:-

  • You have the right to be told what data we hold about you. We may charge you a fee of £10 to cover our costs in dealing with your request.
  • You have the right to stop your data being used, where such use is causing you genuine and substantial distress which is not justified.
  • You have the right to ask for the rectification or erasure of any inaccurate information.

If you are a registered user of our web site, you may access, update and correct the information you provided to us through your account web pages.


We reserve the right to change the terms of this Privacy Policy from time to time, and you are advised to consult our privacy policy regularly.