Privacy Policy Notice

The policy

This privacy policy notice is served by FDN Holding at Unit 610, 24-26 Arcadia Avenue, London N3 2JU, United Kingdom, under the website; [www.mynextlayer.com] and trading name Nextlayer. The purpose of this policy is to explain to you how we control, process, handle and protect your personal information through the business and while you browse or use our websites or any of our mobile applications. If you do not agree to the following policy you may wish to cease viewing / using our products (our websites and or our mobile applications), and or refrain from submitting your personal data to us.

Policy key definitions:

  • "I", "our", "us", or "we" refer to the business, FDN Holding Ltd trading as Nextlayer.
  • "you", "the user" refer to the person(s) using our products (this website and or our mobile applications).
  • GDPR means General Data Protection Act.
  • PECR means Privacy & Electronic Communications Regulation.
  • ICO means Information Commissioner's Office.
  • Cookies mean small files stored on a users computer or device.

Key principles of GDPR:

Our privacy policy embodies the following key principles;

  • Lawfulness, fairness and transparency,
  • Purpose limitation,
  • Data minimisation,
  • Accuracy,
  • Storage limitation,
  • Integrity and confidence,
  • Accountability. 

Processing of your personal data

Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.

  • We are registered with the ICO under the Data Protection Register, our registration number is: ZA540417.
  • Lawful basis: Consent
  • Where our purpose for processing is: to collect usage data and perform semantic analysis on user-uploaded content.
  • Which is necessary to: both continue improving our mobile applications as well as provide an ongoing service to customers.
  • We process your information in the following ways: We collect usage data from our apps and website, this includes app contact data, website cookies, button clicks or taps, product purchases and search terms.
  • Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
  • Sharing your information: We share your usage information with Mixpanel, who currently processes NextLayer's user data so it is structurally relevant to our needs. No personal information is linked to analysed data.
  • NextLayer collects information about how customers use the product, and uses this data to identify product gaps and improve existing products. While this information is useful, Nextlayer recognises the importance of an individual's right to object so enables users to opt-out on request on the website.
  • By using our mobile app, you are bound by our terms and by downloading, consent to these terms, to opt out you will need to delete your account and delete the app from your phone. Your personal data is available to download and copy at all times while you are logged into your account. After account deletion, your personal data will be kept for 6 months, then permanently deleted. 

If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant. 

Examples of prohibited data

It is important to note that certain sensitive information should never be sent to NextLayer.

Sending the following pieces of sensitive information will violate NextLayer’s Terms of Use:

  • Credit Card Information including credit card numbers
  • Social Security and NI Numbers
  • Driver License Numbers
  • Passport Numbers
  • Government Issued Identification Numbers
  • Financial Account Information
  • Personally identifiable information collected from children under the age of 13

Your individual rights

Under the GDPR your rights are as follows. You can read more about your rights in detail here;

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object; and
  • the right not to be subject to automated decision-making including profiling.

You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.

We handle subject access requests in accordance with the GDPR.

Internet cookies

We use cookies on our websites to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen particular messages that we display, to keep you logged into the website where applicable, to monitor your search terms and to display relevant adverts or content or refer you to a third party website.

Some cookies are required to enjoy and use the full functionality of this website and our applications.

We use a cookie control system which allows you to accept the use of cookies, and control which cookies are saved to your device / computer. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.

Cookies that we use are;

Data security and protection

Fair & Transparent Privacy

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.

Where Google's Cloud Vision API is used to analyse your data, your data is encrypted in transit and is addressed by Google's Security White Paper during its analysis.

Mixpanel currently processes NextLayer user usage data so it is structurally relevant to NextLayer's needs. Mixpanel servers that persistently store customer data are hosted by Google Cloud Platform. Data is stored and processed in GCP’s “us-central1” zone in Council Bluffs, IA. GCP’s data centre is SOC 1, SOC 2 and SOC 3 compliant. Additionally, Google logically isolates each customer’s Cloud Platform data from that of other customers and users. Mixpanel automatically removes all data beyond 5 years of age. Find their privacy policy here.

Right to Erasure
We support individuals’ right to erasure through a permanent deletion of personal data and metadata upon request.

Email marketing messages & subscription

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Processing of your personal data" above. Any email marketing messages we send are done so through Mailchimp an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.

Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all lists.

Currently we manage our own EMS.

We hold the following information about you within our EMS system;

  • Email address
  • Subscription time & date