Privacy Policy

We may collect the following types of personal information:

• Contact information: Name, email address, phone number when you contact us or use our services
• Account information: Information you provide when engaging our services
• Usage data: How you interact with our websites and services
• Conversation data: When using Nura (our AI assistant), conversation summaries may be collected with your explicit consent
• Technical data: IP address, browser type, device information for security and analytics

We use your information to:

• Provide and improve our services
• Respond to enquiries and support requests
• Communicate about projects and services
• Follow up on conversations (only with your consent)
• Send relevant updates about our services (where you have opted in)
• Ensure security and prevent fraud
• Comply with legal obligations

Legal basis: We process your data based on:

• Consent - where you have given clear consent (e.g., for marketing or Nura summaries)
• Contract - where processing is necessary to fulfil a contract with you
• Legitimate interests - where we have a legitimate business interest that does not override your rights
• Legal obligation - where we are required to process data by law

Nura is our AI voice assistant available at nura.marbl.codes. When you use Nura, we collect and process data as follows:

Data collected:

• Name: Your first name (required) and last name (optional) to personalise your conversation
• Email address: Required to enable follow-up communication if you consent to receiving a conversation summary
• Phone number: Only if you voluntarily provide it during the conversation for callback purposes
• Conversation transcript: A record of what was discussed, used only for sending summaries to our team when you give explicit consent

How we use this data:

• To greet you by name and provide a personalised experience
• To send conversation summaries to Richard and his team (only with your explicit consent)
• To follow up on enquiries via email or phone (only when you have consented)

Returning visitor functionality:

If you opt-in by checking "Remember me for future visits", your name and email are stored locally in your browser (not on our servers) for up to 14 days. This allows Nura to recognise you on return visits and pre-fill your details. You can clear this data at any time through the Nura interface or your browser settings.

Third-party data sharing:

When you use Nura, your data is shared with the following third-party services. By using Nura, your data becomes subject to these providers' own privacy policies and terms of service:

• ElevenLabs: Nura is powered by ElevenLabs conversational AI. Your voice recordings and conversation transcripts are transmitted to ElevenLabs for processing. Voice recordings and transcripts are stored by ElevenLabs for up to 30 days for quality assurance, analytics, and service improvement purposes, after which they are automatically deleted. Only the account owner (Marbl Codes) has direct access to these recordings, which are used solely for training, analytics, and communication purposes. See the ElevenLabs Privacy Policy for full details.
• AI Language Models: Conversation data may be processed by third-party AI platforms such as Google (Gemini), OpenAI, or Anthropic to generate responses. Data shared with these platforms is subject to their respective privacy policies: Google Privacy Policy, OpenAI Privacy Policy, Anthropic Privacy Policy.

We only share the minimum data necessary to provide the service. We encourage you to review the privacy policies of these third-party providers to understand how your data may be processed.

Legal basis: Consent (Article 6(1)(a) UK GDPR). You provide explicit consent before starting a conversation and before any summary is sent.

Luma is our daily intelligence feed available at luma.marbl.codes. You can subscribe to receive daily digest emails covering AI, Quantum Computing, and Web Development news.

Data collected when subscribing:

• Email address: Required to send you the daily digest
• Category preferences: Which topics you want to receive (AI, Quantum, Web)
• Verification token: A unique token to verify your email address
• Unsubscribe token: A unique token allowing you to unsubscribe at any time

How we use this data:

• To send you daily digest emails based on your category preferences
• To verify your email address before sending digests
• To allow you to unsubscribe at any time

Data storage:

Your subscription data is stored securely in our database. We do not share your email address with third parties for marketing purposes.

Unsubscribing:

Every digest email includes an unsubscribe link. You can also unsubscribe by contacting us at hello@marbl.codes. Upon unsubscribing, your email address will be removed from our mailing list.

Legal basis: Consent (Article 6(1)(a) UK GDPR). You provide explicit consent by subscribing and verifying your email address.

We may share data with trusted third parties who assist in delivering our services:

• Hosting providers: To host our websites and services securely
• Payment processors: To process payments for our services
• Analytics tools: To understand how our services are used (anonymised where possible)
• Email service providers: To send communications you have requested
• AI service providers: As detailed in the Nura section above

We do not sell your personal data.

We may also disclose data where required by law or to protect our legal rights.

We retain personal data only as long as necessary for the purposes outlined above, or as required by law:

• Contact and enquiry data: Retained for as long as necessary to respond to your enquiry, then deleted unless you become a client
• Client data: Retained for 6 years after the end of our business relationship for legal and accounting purposes
• Nura conversation data: Conversation summaries are retained for business purposes; ElevenLabs retains voice recordings for up to 30 days
• Local storage data: Automatically expires after 14 days if you opted in to "Remember me"

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

• Right of access: Request a copy of your personal data
• Right to rectification: Request correction of inaccurate data
• Right to erasure: Request deletion of your data ("right to be forgotten")
• Right to restrict processing: Request that we limit how we use your data
• Right to data portability: Receive your data in a portable format
• Right to object: Object to processing based on legitimate interests or direct marketing
• Right to withdraw consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, contact us at hello@marbl.codes

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data protection rights have been violated.

We take appropriate technical and organisational measures to protect your personal data, including:

• Secure HTTPS connections on all our websites
• Regular security updates and monitoring
• Access controls limiting who can access personal data
• Secure hosting with reputable providers

While we take all reasonable precautions, no data transmission over the internet can be guaranteed to be 100% secure.

Some of our third-party service providers may process data outside the UK. When this occurs, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by the UK government
• Transfers to countries with adequacy decisions
• Binding corporate rules where applicable

For Nura specifically, data may be processed in the United States by ElevenLabs, Google, OpenAI, and Anthropic under their respective data protection frameworks.

If you have questions about this privacy policy or wish to exercise your data protection rights, please contact us:

Email: hello@marbl.codes

Address: Marbl Codes (MEM Digital Ltd), 5 Burford Way, Wellingborough, Northamptonshire, NN8 2JF

Data Protection Officer: Richard Bland