1. Who we are

This policy is issued by Neuraplicity Ltd ("Neuraplicity", "we", "us", "our"), a company registered in England, operating the Access and Nexus OS platforms together with the neuraplicity.ai website (together, the "Services"). We are the data controller for the personal data described in this policy, unless we tell you otherwise for a specific feature.

If you have any questions about this policy or how we handle personal data, contact us at contact@neuraplicity.ai.

2. Data we collect

What we collect depends on whether you're browsing the site, setting up a practice through Access, or running a practice on Nexus OS.

3. How we use your data

We rely on the following legal bases under UK GDPR (and, where relevant, EU GDPR) to process personal data:

• Performance of a contract – to set up your practice through Access, to operate Nexus OS, to process payments, and to provide support.
• Legitimate interests – to keep the Services secure, to understand how they're used so we can improve them, and to communicate with you about your account. We balance this against your rights and won't rely on it where your interests override ours.
• Consent – for optional communications such as product updates, where we ask for it separately; to connect a third-party account such as Google Workspace; and to contribute anonymised data to the Collective Intelligence Layer. All of these can be withdrawn at any time.
• Legal obligation – where we need to keep or disclose data to comply with the law, for example tax and accounting records.

4. How our AI agents use data

Access and Nexus OS use AI agents to draft positioning, pricing, legal and brand outputs (including your Voice Profile), and to surface outreach, relationship, practice, post-call and voice intelligence. These agents process the practice and client data you provide in order to generate the specific output you've asked for.

To do this, we send the relevant practice and client data to third-party AI model providers, who process it as our data processor and not for their own purposes. We use a mix of providers, routed automatically depending on the task: Anthropic (the Claude models), OpenAI, and Google (the Gemini models, processed in Google's London region). Under our agreement with each provider, data you submit through their commercial API is not used to train their underlying models. Anthropic and OpenAI process data in the United States, so sending data to them is an international transfer: see section 8 for the safeguards that apply.

During Structure, the entity details you provide are checked against the relevant public company registry (for example Companies House, CRO, Handelsregister, INPI, KVK, or the relevant US Secretary of State) to flag any mismatch in status or name: see section 7 for how this check is shared.

Where an agent produces a suggested action, such as an outreach message, a proposal, or a pricing recommendation, it is queued for your review rather than sent or acted on automatically, unless you've explicitly configured otherwise. Where an agent proposes information to be saved to your practice record, such as a client note, a task, or a relationship update, it's held for your review and approval through the Memory Approval Gate before it's written to your account.

5. Connected accounts

Nexus OS can connect to third-party accounts and tools you already use, so the Intelligence Engine can work from your real calendar, inbox, documents and call history rather than data re-entered by hand. The same principles apply to every connected account, whichever provider it's with:

• We access only the data needed to power the specific features you've enabled for that connection: nothing is pulled "just in case".
• Data from a connected account is used to power the Services for you: to brief you, draft communications, and populate your practice records, and not for any other purpose.
• Where connected-account data would update your practice record, it passes through the Memory Approval Gate for your review before it's saved, in the same way as any other AI-generated output.
• You can disconnect any connected account at any time from your account settings, which stops any further access; data already imported remains until you delete it or close your account, as described in section 9 (Data retention).
• We do not use connected-account data to serve ads, and we do not use it to train generalised AI/ML models.

Google Workspace Live

Where you connect a Google Workspace account, we access:

• Calendar – event titles, times and attendees, to populate your daily briefing and pre-meeting preparation.
• Gmail – message metadata and, where needed for a specific feature such as a communication draft, message content.
• Drive – documents you've stored there, where relevant to a client or project you're working on.
• Meet transcripts – call transcripts, to extract commitments, next steps and relationship context.

Planned integrations

The following connections are planned but not yet live. When each launches, we'll add the specific data categories accessed to this section and update the "Last updated" date, before that integration becomes available to connect:

• Microsoft 365 / Outlook (via Microsoft Graph) – calendar, mail and OneDrive data, under Microsoft's own terms for third-party app access to Graph data.
• Zoom and Fireflies – meeting recordings and transcripts, for the same commitment- and relationship-extraction purposes as Google Meet transcripts above.
• DocuSign – document and e-signature status, to reflect signed agreements in your practice records.
• Xero – accounting and invoicing data, to reconcile billing inside Nexus OS.

We'll only request access to a new connected account with your explicit, separate consent for that connection: connecting one account never automatically connects another.

6. Collective Intelligence Layer

Separately from your own Client Memory, Nexus OS operates an opt-in Collective Intelligence Layer: anonymised, aggregated patterns drawn from many consultants' use of the platform: for example, which frameworks tend to be effective for a given problem type, or how well a search query performs, used to improve the platform for everyone.

This is entirely separate from your individual client data:

• Participation is opt-in, asked for separately from any other consent, and you can withdraw at any time from your account settings.
• Data contributed to this layer is anonymised before it's aggregated: no client names, company names, or other identifying details are included.
• We only report or use patterns where at least 50 consultants' data contributes to them, so no individual consultant's activity can be inferred from the results.
• Withdrawing consent stops future contributions; it doesn't retroactively remove your data from patterns already aggregated, since those patterns no longer contain anything that identifies you individually.

7. Who we share data with

We don't sell personal data. We share it only where necessary to run the Services:

• AI model providers, who process the practice and client data you submit in order to generate agent outputs, under a data processing agreement: Anthropic, OpenAI and Google, routed automatically depending on the task (see section 4).
• Infrastructure and hosting providers, who store and process data on our behalf under a data processing agreement.
• Public company registries, which we query with the entity details you provide during Access to verify what you've told us: we don't send them anything beyond what's needed for that check.
• Connected-account providers, to the extent needed to provide the features you've enabled for that connection: currently Google, for Google Workspace, in line with Google's own privacy terms and our obligations under Google's API Services User Data Policy. As further integrations go live (see section 5), the relevant provider is added here.
• Referral partners, where you interact with a sponsored partner card during Access: currently limited to showing the card and logging that it was shown or clicked; we don't send your data to the partner unless you choose to proceed with them.
• Payment processors, to handle billing for Access and Nexus OS.
• Email and communication providers, to send transactional messages and, where you've agreed, product updates.
• Professional advisers and regulators, where required by law or to protect our legal rights.
• A buyer, if we're involved in a merger, acquisition or asset sale: we'll tell you before your data is transferred and becomes subject to a different privacy policy.

8. International transfers

Some of our infrastructure and service providers process data outside the UK. The most significant of these are two of the AI model providers described in section 4: Anthropic and OpenAI, both based in the United States. Every time an AI agent routes a request to one of these providers, your practice or client data is transferred outside the UK. Our third AI model provider, Google, processes data for us in its London (europe-west2) region, so this does not involve an international transfer. This section also covers verifying entity details against non-UK public registries as part of Access, and any other service provider that processes data outside the UK.

Where this happens, we put appropriate safeguards in place before the transfer takes place, principally the UK International Data Transfer Addendum or the EU Standard Contractual Clauses incorporated into our data processing agreement with the provider. Where a provider is separately certified under the UK Extension to the EU-US Data Privacy Framework, we may rely on that instead for the categories of data it covers. You can ask us for details of the safeguards that apply to your data at contact@neuraplicity.ai.

9. Data retention

We keep personal data for as long as your account is active, plus a reasonable period afterwards to meet legal, accounting and tax obligations, resolve disputes, and enforce our agreements. Practice and client data you've entered into Nexus OS is retained until you delete it or close your account, after which it is deleted or anonymised within a reasonable period, subject to any legal retention requirements.

10. Your rights

Under UK GDPR, you have the right to:

• Be informed about how we process your data: this policy is part of that.
• Access the personal data we hold about you.
• Rectification of inaccurate or incomplete data.
• Erasure of your data in certain circumstances.
• Restrict processing of your data in certain circumstances.
• Data portability – receive your data in a portable format, or have it transferred to another provider, where the processing is based on consent or contract and carried out by automated means.
• Object to processing based on legitimate interests or for direct marketing.
• Rights related to automated decision-making – Neuraplicity does not use fully automated decisions that produce legal or similarly significant effects about you without human review.

To exercise any of these rights, email contact@neuraplicity.ai. We may ask you to verify your identity before acting on a request.

11. Cookies

We use a small number of strictly necessary cookies to keep you signed in and to remember basic preferences. Where we use any analytics or non-essential cookies, we'll ask for your consent first and give you a way to change your mind. You can also control cookies through your browser settings.

12. Children's data

The Services are intended for independent consultants and businesses, and are not directed at, or knowingly used by, anyone under 18. If you believe a child has provided us with personal data, contact us and we'll remove it.

13. Changes to this policy

We may update this policy from time to time, for example to reflect changes in the law or in how the Services work. We'll post the updated version here and update the "Last updated" date above; for material changes, we'll also aim to let you know directly.

14. Contact us and complaints

Questions, requests or complaints about this policy or our handling of your personal data can be sent to contact@neuraplicity.ai. If you're not satisfied with our response, you also have the right to lodge a complaint with the UK's data protection regulator, the Information Commissioner's Office (ICO), or with the supervisory authority in your own EU member state if applicable.

1. Acceptance of these terms

These Terms of Service (the "Terms") are a legal agreement between you, or the business you represent ("you", "your"), and Neuraplicity Ltd, a company registered in England ("Neuraplicity", "we", "us", "our"). They govern your access to and use of the Access and Nexus OS platforms and the neuraplicity.ai website (together, the "Services").

By creating an account, subscribing to, or otherwise using the Services, you accept these Terms. If you're accepting on behalf of a company or other organisation, you confirm you have the authority to bind that organisation, and "you" refers to that organisation as well as yourself.

If you don't agree to these Terms, you shouldn't use the Services.

2. Definitions

1. "Access" means the one-time, guided setup platform delivered across five sequential agents (Define, Structure, Price, Present and Express), covering positioning, legal and business setup, pricing, brand and presence, and a Voice Profile used to keep later AI-generated content in the consultant's own voice.
2. "Nexus OS" means the subscription practice-management platform, including the relationship graph, pipeline, and background intelligence agents.
3. "Content" means any data, text, files or other material submitted to, or generated through, the Services.
4. "Subscriber" means the individual or business that holds an account for the Services.

3. Eligibility and business use

The Services are provided for use by independent consultants and businesses in the course of their trade or profession, and are not intended for personal, consumer use. By using the Services, you confirm that you're at least 18 years old and are using them for business purposes.

4. The services

Access provides a guided setup across five agents (Define, Structure, Price, Present and Express), producing a positioning canvas, legal and entity setup guidance (including a check of the entity you provide against the relevant public company registry), a pricing model, a brand and presence kit, and a Voice Profile. Nexus OS provides ongoing practice management through an Intelligence Engine that operates in two modes (a daily briefing, task and communication mode, and a structured Deep Work analysis mode), both governed by the Memory Approval Gate, together with background agents (outreach, relationship, practice, post-call and voice intelligence) and a practice infrastructure (CRM, projects, time tracking, billing) that builds itself from that activity.

Nexus OS usage is metered through an AI credits system. Each plan includes a monthly credit allowance; credits are consumed as you use the Intelligence Engine and other AI features, and additional credits can be purchased as top-ups. See section 6 (Fees and payment) for how this affects billing.

We aim to keep the Services available and reliable, but we don't guarantee uninterrupted or error-free operation, and we may change, suspend or discontinue features from time to time, including to reflect changes in our product, our users' needs, or applicable law.

5. Accounts and registration

You're responsible for the accuracy of the information you give us when setting up an account, and for keeping your login credentials secure. You're responsible for activity that happens under your account, and should tell us promptly if you suspect unauthorised access.

6. Fees and payment

Access is billed as a one-time setup fee. Nexus OS is billed on a recurring subscription basis at the rate shown at sign-up. Fees are exclusive of any applicable taxes unless stated otherwise. Subscription fees are billed in advance and, except where required by law or stated otherwise at the point of sale, are non-refundable. We'll give you reasonable notice of any pricing changes before they take effect for your account.

Nexus OS plans include a monthly allowance of AI credits, consumed as you use the Intelligence Engine and other metered features. If your credit balance runs low, some features may be limited or restricted until your balance renews or you purchase a top-up; we'll show you your balance and warn you before this happens. Top-up credit purchases are billed at the time of purchase and are non-refundable, except where required by law. If you've enabled automatic top-up, we'll charge your payment method automatically when your balance falls below the threshold you've set, and you can turn this off at any time in your account settings.

7. Your content and data

You retain ownership of the practice, client and business data you submit to the Services ("Your Content"). You grant us a licence to host, process and use Your Content solely to provide, maintain and improve the Services for you. You're responsible for having the right to share any third-party personal data (such as your clients' contact details) that you upload, and for using the Services in line with your own obligations to those third parties. Our handling of personal data is described in our Privacy Policy.

Where you connect a third-party account such as Google Workspace, you're responsible for having the right to share the calendar, email, document and meeting data that connection makes available to us, including in respect of any third parties (such as clients or colleagues) who appear in that data. Where you use the Services to process meeting recordings or transcripts, you're responsible for obtaining any consent required from meeting participants under applicable law before doing so.

8. AI-generated outputs

Where an agent proposes an action that affects a third party, such as an outreach message, it's queued for your approval rather than sent automatically, unless you've configured otherwise. Where an agent proposes information to be saved to your practice record, such as a client note, a task, or a relationship update, it's held for your review and approval through the Memory Approval Gate before it's written to your account, rather than saved automatically. You remain responsible for actions taken under your account, including those initiated by an agent with your approval.

9. Acceptable use

You agree not to:

• use the Services for any unlawful purpose, or in a way that infringes anyone else's rights;
• attempt to gain unauthorised access to the Services, other accounts, or our systems;
• upload malicious code, or content you don't have the right to share;
• use the Services to harass, deceive or defraud any person; or
• reverse engineer or attempt to extract the underlying models or source code of the Services, except to the extent the law gives you the right to do so.

We may suspend or restrict access where we reasonably believe these Terms have been breached.

10. Third-party services

The Services may link to, or integrate with, third-party tools and platforms. We're not responsible for the content, accuracy, or practices of third-party services, and your use of them is governed by their own terms and privacy policies.

If you connect Google Workspace or another third-party account, that connection is also governed by that provider's own terms. We access only the calendar, email, document and meeting data needed to power the features you've enabled, and you can disconnect a connected account at any time from your account settings; see our Privacy Policy for details of how this data is used.

11. Our intellectual property

The Services, including their software, design, templates, agent prompts and underlying systems, are owned by or licensed to Neuraplicity and are protected by intellectual property laws. Nothing in these Terms transfers any of our intellectual property rights to you, other than the right to use the Services in line with these Terms.

12. Warranties and disclaimers

The Services are provided "as is" and "as available". To the fullest extent permitted by law, we exclude all warranties, express or implied, about the Services, including that they will be uninterrupted, error-free, or fit for a particular purpose, beyond what is expressly stated in these Terms.

13. Limitation of liability

Nothing in these Terms limits or excludes our liability for death or personal injury caused by our negligence, for fraud, or for anything else that can't lawfully be limited or excluded. Subject to that, to the fullest extent permitted by law, we won't be liable for any indirect or consequential loss, or for loss of profits, revenue, business, contracts or anticipated savings, and our total liability arising out of or in connection with the Services will not exceed the greater of £100 or the amount you've paid us in the twelve months before the claim arose.

14. Suspension and termination

You may stop using the Services and close your account at any time. We may suspend or terminate your access if you materially breach these Terms and don't remedy that breach within a reasonable period of being notified, or immediately where necessary to protect the security or integrity of the Services. On termination, the licence to use the Services ends, though provisions that by their nature should survive (including ownership, disclaimers, and limitation of liability) will continue to apply.

15. Changes to these terms

We may update these Terms from time to time, for example to reflect changes to the Services or to applicable law. We'll post the updated Terms here and update the "Last updated" date; material changes will be notified to active subscribers where practicable. Continued use of the Services after changes take effect means you accept the updated Terms.

16. Governing law and disputes

These Terms are governed by the laws of England and Wales, and the courts of England and Wales will have exclusive jurisdiction over any dispute arising out of or in connection with them, subject to any mandatory consumer protections that may apply in your jurisdiction.

17. Contact us

Questions about these Terms can be sent to contact@neuraplicity.ai.

1. Our commitment

Neuraplicity Ltd wants the neuraplicity.ai website, Access and Nexus OS to be usable by everyone, including people who rely on assistive technology such as screen readers, screen magnification, voice control, or keyboard-only navigation. Accessibility is something we actively review and improve, rather than treat as a one-off checkbox.

2. Conformance status

Our target standard is the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. "Partially conformant" means that some parts of the content don't yet fully meet the standard: we haven't claimed full conformance because we'd rather be accurate about where we are.

Neuraplicity is a private company, not a public sector body, so we're not in scope of the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018. We're aiming for WCAG 2.1 AA anyway, because it's a reasonable, well-established bar, and because the UK Equality Act 2010 requires reasonable steps to avoid putting disabled people at a substantial disadvantage.

3. What we've built in

• A "skip to content" link at the start of every page, so keyboard users can bypass repeated navigation.
• Semantic landmarks – a single <main> region per page, proper heading structure, and labelled navigation.
• Visible focus indicators on links, buttons and form fields, tuned to meet minimum contrast requirements against both light and dark backgrounds.
• Colour combinations checked against WCAG AA contrast thresholds for text and meaningful icons.
• Support for prefers-reduced-motion, so animations and transitions are minimised for people who've asked their system for that.
• Form fields with associated labels, and status messages (such as form confirmation) exposed to assistive technology.
• Alt text on meaningful images, and decorative images and icons hidden from assistive technology so they don't add noise.

4. Known limitations

We know of the following gaps, and we're working through them:

• Some card-style layouts use heading levels chosen for visual hierarchy as much as document structure; we're reviewing these for stricter WCAG 1.3.1 conformance.
• Third-party embedded content (such as fonts or, where used, embedded scheduling or payment widgets) is outside our direct control, and may not fully match this statement.
• Some longer-form pages haven't yet been tested with every combination of screen reader and browser; our primary testing covers current versions of major browsers with common screen readers.

5. Compatibility with assistive technology

The Services are designed to work with recent versions of major browsers (Chrome, Firefox, Safari, Edge) combined with commonly used assistive technology, including screen readers such as NVDA, JAWS and VoiceOver, and with keyboard-only navigation.

6. Feedback and reporting an issue

If you find an accessibility barrier anywhere on neuraplicity.ai, Access or Nexus OS, we want to hear about it. Please email contact@neuraplicity.ai with:

• the page or feature where you ran into the problem;
• what you were trying to do; and
• the browser, device and any assistive technology you were using, if relevant.

We aim to acknowledge accessibility reports within 5 working days, and to give you a clear next step or timeframe for a fix.

7. Enforcement

This statement is a voluntary commitment rather than a statutory one, since Neuraplicity isn't a public sector body. If you feel we haven't responded reasonably to an accessibility concern, you can raise it with the Equality and Human Rights Commission, which enforces the Equality Act 2010 in England.