Privacy Policy

Surely respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store and protect personal information when you visit www.surelylabs.io, submit a problem, contact us, take part in research or testing, or otherwise interact with Surely.

For the purposes of UK data protection law, the data controller is Surely, operated by LearnHow2.ai. Email: Hello@LearnHow2.ai

In this policy, “Surely”, “we”, “us” and “our” refer to the organisation operating the Surely website and services.

1. What information we collect

We may collect information that you provide directly to us.

This can include your name, email address, information submitted through forms, problems or frustrations you tell us about, current workarounds, how frequently you experience a problem, feedback about products or experiments, research responses and your interest in testing potential solutions.

Where a form makes your name or email address optional, you may submit the form without providing them.

We may also collect technical information when you use the website, such as your IP address, browser type, device type, pages visited, approximate location derived from technical information, referral source and information collected through cookies or similar technologies.

If you communicate with us, we may retain relevant correspondence and information you provide.

2. Problem submissions

Surely exists to identify everyday problems and explore whether there may be better ways to solve them.

If you submit a problem, we may review, categorise, analyse and combine it with similar problems reported by other people.

We may publish or discuss anonymised or aggregated versions of problems, themes and insights on our website, social media, research materials or other Surely content.

We will not intentionally publish your name, email address or other information that directly identifies you in connection with a problem submission without your permission.

Please do not include confidential information, passwords, financial account information or unnecessary personal information about another person in a problem submission.

You should also avoid providing sensitive personal information, such as detailed medical information, ethnicity, religious beliefs, political opinions, sexual orientation, biometric information or similar information unless we specifically request it and explain why it is required.

If sensitive personal information is submitted unexpectedly, we may remove, anonymise or delete it where appropriate.

3. Publicly available problem research

Surely may review publicly available websites, forums, reviews, social platforms and other public sources to identify recurring problems people experience.

Our objective is to understand the problem, rather than create profiles about individual people.

Where possible, information used in our problem database is summarised or anonymised and names, usernames and unnecessary identifying details are not retained.

We may retain links to original public sources where they provide useful evidence of a problem.

4. How we use your information

We use personal information where we have a lawful reason to do so.

We may use information to operate and improve the Surely website, review problem submissions, identify recurring problems, investigate potential solutions, conduct research, invite people to participate in testing, respond to enquiries, improve experiments and products, maintain the security of our systems and comply with legal obligations.

For most problem submissions and ordinary correspondence, we rely on our legitimate interests in researching problems, operating Surely, improving our services and responding to people who choose to engage with us.

Where you specifically ask to participate in research, testing or communications that require consent, we may rely on your consent.

Where processing is necessary to comply with a legal obligation, we rely on legal obligation.

If we provide a paid product or service to you in the future, certain processing may also be necessary to perform a contract with you.

Where we rely on legitimate interests, we consider whether our use of the information is necessary and proportionate and whether your rights and interests override ours.

5. Research and product testing

If you tell us that you are interested in helping test a solution or participating in research, we may contact you about relevant research or experiments.

Agreeing to participate is voluntary.

You can change your mind at any time by contacting us at Hello@LearnHow2.ai.

If we wish to record an interview, research session or testing session, we will tell you before the recording begins and obtain any consent required.

We may combine feedback from multiple participants and use anonymised findings to improve products, publish research findings or explain what we have learned.

6. Marketing communications

We will not add you to a general marketing mailing list merely because you submitted a problem.

Where we ask you to subscribe to newsletters or marketing communications, we will make this clear.

You can unsubscribe from marketing communications at any time using the unsubscribe link in the message or by contacting Hello@LearnHow2.ai.

Withdrawing marketing consent does not affect the lawfulness of processing that took place before consent was withdrawn.

7. Cookies and analytics

Our website may use cookies and similar technologies.

Some cookies are necessary for the website to operate, for example for security, functionality and remembering privacy preferences.

Other cookies may be used for analytics, measurement or marketing.

Where consent is legally required, non-essential cookies will not be activated until you have made a choice.

You can change or withdraw your cookie preferences at any time. Our Cookies Policy explains the technologies we use and your choices.

UK rules generally require websites to explain what cookies do and obtain consent before setting non-essential cookies.

8. Who we share information with

We do not sell personal information.

We may share personal information with trusted service providers where this is necessary to operate Surely.

These may include website hosting and website-management providers, email and communications providers, analytics providers, technology providers, professional advisers and other suppliers that help us operate the website or conduct research.

Where a provider processes personal information on our behalf, we require appropriate contractual and security protections.

We may also disclose information where we reasonably believe this is necessary to comply with the law, respond to a lawful request, establish or defend legal rights, prevent fraud or misuse, or protect the security of our users, systems or services.

If Surely or substantially all of its business or assets are sold, merged or transferred, relevant information may be transferred as part of that transaction, subject to applicable data protection law.

9. International transfers

Some technology providers we use may process information outside the United Kingdom.

Where personal information is transferred outside the UK and UK data protection law requires additional protection, we will use a lawful transfer mechanism.

This may include UK adequacy regulations or appropriate safeguards such as the UK International Data Transfer Agreement or UK Addendum.

Where required, we also carry out the appropriate assessment of the protections applying to the transfer.

You can contact us at Hello@LearnHow2.ai if you would like more information about safeguards relating to international transfers.

10. How long we keep personal information

We only retain identifiable personal information for as long as we reasonably need it for the purpose for which it was collected.

Problem submissions and related contact information will normally be retained for up to 24 months after our last meaningful interaction with you, after which identifying information will be deleted or anonymised unless we have a legitimate reason to retain it longer.

Research and tester information will normally be retained for up to 24 months after the relevant research or testing activity ends, unless you continue participating in Surely activities.

Marketing contact information may be retained until you unsubscribe. We may then retain a minimal suppression record so that we know not to contact you again.

Security and technical logs may normally be retained for up to 12 months, unless they are required for investigating a security incident.

Information that has been genuinely anonymised so that it can no longer identify an individual may be retained for longer because it is no longer personal information.

We may retain information for longer where required by law or where reasonably necessary to establish, exercise or defend legal claims.

11. Security

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss or misuse.

Access to personal information is limited to people and service providers who reasonably need access for the purposes described in this policy.

However, no internet service or electronic storage system can be guaranteed to be completely secure.

If we become aware of a personal-data breach, we will assess it and take any action required under applicable data protection law.

12. Your data protection rights

Depending on the circumstances and the lawful basis we rely on, UK data protection law may give you rights to request access to your personal information, have inaccurate information corrected, request deletion, request restriction of processing, receive certain information in a portable format and withdraw consent where processing is based on consent.

You may also have the right to object to certain uses of your information. Where we process your personal information on the basis of legitimate interests, you have the right to object to that processing in certain circumstances.

You can exercise your rights by contacting Hello@LearnHow2.ai.

We may need to verify your identity before acting on a request.

These rights are not absolute and may be subject to exceptions under applicable law.

13. Automated decision-making

We do not currently use personal information to make decisions about individuals solely by automated means where those decisions produce legal or similarly significant effects.

If this changes, we will update this Privacy Policy and provide any additional information required by law.

14. Children

Surely’s website and general problem-submission services are not designed specifically for children under 16.

We do not knowingly seek to collect personal information from children through our general website forms.

If we conduct research specifically involving children in the future, we will introduce appropriate privacy information, permissions and safeguards for that activity.

If you believe a child has provided us with personal information inappropriately, please contact Hello@LearnHow2.ai.

15. Links to other websites

Our website may contain links to websites, products or services operated by other organisations.

We are not responsible for the privacy practices of those organisations.

You should review their privacy information before providing them with personal information.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our website, services, technology or legal obligations.

The current version will always be published on this page and the “Last updated” date will be changed when the policy is materially revised.

Where appropriate, we may also notify users of significant changes by other means.

17. Contact us

If you have a question about this Privacy Policy, how we use personal information or your data-protection rights, contact Surely at Hello@LearnHow2.ai.

If you are unhappy with how we use your personal information, please contact us first so that we have an opportunity to address your concern.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.