Introduction
This Privacy Notice explains how we collect, use, and protect your personal data when you use our website and the Lifelight Application. 
We are a ‘data controller’ in certain circumstances – e.g. personal data submitted to us through our website. For patient data, Xim is what is known as the ‘data processor’ and not the ‘data controller.’ The healthcare organisation is the data controller for patient data. 
Who are we?
Xim’s registered office is: The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP 
We are a company registered in England and Wales under company number: 3699022 
Our Information Commissioner’s Office (ICO) Registration number is: ZA24174 
We gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.  
The individual responsible for data protection is Claire Robinson who can be contacted at: The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP. 
Cookies
Our site uses “cookie” technology to enhance your user experience. A cookie is a small piece of text stored by your browser on your computer, at the request of our server. Please refer to Lifelight’s cookie declaration for information about the cookies we use.
Change your consent here.
How we use your personal data (legal basis for processing)
Xim Limited will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. 
As a data controller, we process your personal data on the following lawful bases: 
Legal obligation – where we are required to retain data for accounting, tax, or regulatory purposes. 
Legitimate interests – to provide our products, services, and support to customers and prospective customers, and to ensure the security and functionality of our website and systems. 
Recognised legitimate interests under the Data Protection and Digital Information Act – where applicable, for activities such as service improvement, analytics, or customer engagement, provided your rights and freedoms are not overridden. 
How we use your personal data (legal basis for processing)
Xim Limited will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. 
As a data controller, we process your personal data on the following lawful bases: 
Legal obligation – where we are required to retain data for accounting, tax, or regulatory purposes. 
Legitimate interests – to provide our products, services, and support to customers and prospective customers, and to ensure the security and functionality of our website and systems. 
Recognised legitimate interests under the Data Protection and Digital Information Act – where applicable, for activities such as service improvement, analytics, or customer engagement, provided your rights and freedoms are not overridden. 
How we use your personal data (legal basis for processing)
Xim Limited will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. 
As a data controller, we process your personal data on the following lawful bases: 
Legal obligation – where we are required to retain data for accounting, tax, or regulatory purposes. 
Legitimate interests – to provide our products, services, and support to customers and prospective customers, and to ensure the security and functionality of our website and systems. 
Recognised legitimate interests under the Data Protection and Digital Information Act – where applicable, for activities such as service improvement, analytics, or customer engagement, provided your rights and freedoms are not overridden. 
Legitimate interests
We have a legitimate interest in improving our services. We may collect behavioural information to understand how our app is used, support product improvement, audit purposes, and incident resolution. 
Legitimate interests
We have a legitimate interest in improving our services. We may collect behavioural information to understand how our app is used, support product improvement, audit purposes, and incident resolution. 
Legitimate interests
We have a legitimate interest in improving our services. We may collect behavioural information to understand how our app is used, support product improvement, audit purposes, and incident resolution. 
Your data, your rights, your choices
You have the following rights under data protection law: 
The right to be informed 
The right of access 
The right to rectification 
The right to erasure (“the right to be forgotten”) 
The right to restrict processing 
The right to object to processing 
The right to data portability 
The right to withdraw consent at any time 
The right to be informed about automated decision-making and profiling 
The right to lodge a complaint with us. Please contact us in the first instance. 
If it is unresolved, you have the right to escalate your concern to the Information Commissioner’s Office (ICO) 
If you are dissatisfied with the ICO’s response, you have the right to appeal to the Information Rights Tribunal within 28 days 
To exercise any of these rights, please email: dpo@lifelight.ai 
Or write to: Xim Limited, The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP. 
Your data, your rights, your choices
You have the following rights under data protection law: 
The right to be informed 
The right of access 
The right to rectification 
The right to erasure (“the right to be forgotten”) 
The right to restrict processing 
The right to object to processing 
The right to data portability 
The right to withdraw consent at any time 
The right to be informed about automated decision-making and profiling 
The right to lodge a complaint with us. Please contact us in the first instance. 
If it is unresolved, you have the right to escalate your concern to the Information Commissioner’s Office (ICO) 
If you are dissatisfied with the ICO’s response, you have the right to appeal to the Information Rights Tribunal within 28 days 
To exercise any of these rights, please email: dpo@lifelight.ai 
Or write to: Xim Limited, The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP. 
Your data, your rights, your choices
You have the following rights under data protection law: 
The right to be informed 
The right of access 
The right to rectification 
The right to erasure (“the right to be forgotten”) 
The right to restrict processing 
The right to object to processing 
The right to data portability 
The right to withdraw consent at any time 
The right to be informed about automated decision-making and profiling 
The right to lodge a complaint with us. Please contact us in the first instance. 
If it is unresolved, you have the right to escalate your concern to the Information Commissioner’s Office (ICO) 
If you are dissatisfied with the ICO’s response, you have the right to appeal to the Information Rights Tribunal within 28 days 
To exercise any of these rights, please email: dpo@lifelight.ai 
Or write to: Xim Limited, The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP. 
Safeguarding Measures
We apply security controls and best practices including SSL, encryption, access restrictions, and firewalls to protect your personal data. 
Transfers outside the UK/EU
We only transfer your data outside the UK/EEA where adequate safeguards are in place. 
How Long We Keep Your Data
We retain data only as long as necessary. We are required to retain some personal data for 6 years for tax purposes. For marketing, we retain data until you withdraw consent. 
Special Categories Data (including patient data)
Where we process special category data on behalf of healthcare providers (such as NHS Trusts), we do so under a data processing agreement. The controller typically relies on Article 6(1)(e) – public task – and Article 9(2)(h) – healthcare purposes. Xim, as processor, follows the controller’s lawful basis and instructions, and does not independently determine the lawful basis. Similarly, controllers are responsible for applying the national data opt-out. Where instructed by a controller, Xim complies with their direction.