Privacy Policy
The NICU Space CIC | Effective Date: June 2026 | Version 1.0
In brief: what you need to know
- The NICU Space CIC is a peer support community for NICU parents and families. We handle your personal data with care and respect.
- We only collect what we need to run the community and keep you informed.
- We use some AI tools for internal administration only. These are never used to monitor members or make decisions about your membership.
- You have rights over your data, including the right to access, correct, or request deletion of your information.
- You have the right to complain to us directly about how we handle your personal data. We will acknowledge your complaint within 30 days.
- You can also complain to the Information Commissioner's Office (ICO) at any time.
1. Who We Are
The NICU Space CIC is a Community Interest Company providing peer support, resources, and community for parents and families who have experienced neonatal intensive care.
CIC registration number: 16460504
ICO Registration number: ZC179976
Data controller contact:
Dr Frankie Harrison, Director
Email: hello@miraclemoon.co.uk
Website: www.miraclemoon.co.uk
2. Personal Data We Collect
a) Community members (Circle platform)
- Name and email address
- Profile information you choose to share
- Posts, comments, and messages you make within the community
- Event attendance records
b) Website visitors
- IP address and browser metadata
- Pages visited (if you accept analytics cookies)
- Name, email, and message content (if you use a contact form)
c) People who attend events or meet-ups
- Name and contact details
- Attendance records
d) Financial information
- Payment records for any paid membership or events (processed via Stripe)
A note about sensitive information shared in the community:
Members of The NICU Space often share deeply personal experiences relating to premature birth, neonatal illness, trauma, and loss. We treat everything shared in the community with the utmost sensitivity and confidentiality. Moderators and staff may read posts to support safe community management, but content is never shared outside the community without your consent except where required by law (for example, in a safeguarding situation).
3. Lawful Basis for Processing
| Processing activity | Lawful basis |
|---|---|
| Running the Circle community platform | Contract - necessary to provide the community membership you have signed up for |
| Sending community updates and communications | Consent - you opt in and can unsubscribe at any time |
| Processing payments for paid memberships or events | Contract and legal obligation |
| Managing events and meet-ups | Contract and legitimate interests |
| Safeguarding disclosures | Legal obligation and/or vital interests |
| Zoom meeting notes (team and organisational meetings only) | Legitimate interests |
| Website analytics (if accepted) | Consent |
| Funding applications and reporting | Legitimate interests - operating the CIC and securing funding for the community |
4. How We Use Personal Data
- To run and moderate The NICU Space community on Circle
- To send updates, resources, and event information to members
- To organise and manage events and meet-ups
- To process payments and keep financial records
- To meet our legal and regulatory obligations as a CIC
- To apply for funding and report to funders (using anonymised or aggregate data wherever possible)
5. Third-Party Systems and Data Processors
a) Circle (community platform)
The NICU Space community is hosted on Circle. Circle processes member names, email addresses, profile information, and community content on our behalf. Circle may process data outside the UK - please refer to Circle's privacy policy for details of their data handling and transfer mechanisms.
b) Stripe (payments)
We use Stripe to process any payments for membership or events. Stripe handles payment data directly and we do not store card details.
c) Zoom (meetings)
We use Zoom for organisational meetings, team calls, and some community events. Zoom's AI note-taking feature may be used in internal team meetings and planning calls.
Zoom AI note-taking is not used in community peer support sessions or member-facing spaces without explicit notice and consent.
d) Claude (AI assistant - administration only)
We use Claude, an AI assistant by Anthropic, for internal administrative tasks such as drafting documents, planning content, and operational work. Claude is used by staff for organisational purposes only and is not used to monitor, assess, or make decisions about community members.
We do not input identifiable member data into Claude.
e) Klaviyo (email communications)
We use Klaviyo to manage email communications with our community. Klaviyo processes names, email addresses, and engagement data on our behalf.
6. Who We Share Data With
We share personal data only when necessary and with a lawful basis:
- Data processors listed above, under data processing agreements
- Funders - using anonymised or aggregate data only, unless you have given specific consent
- Safeguarding bodies or emergency services - where necessary to protect someone from serious harm
- Professional advisers - under confidentiality obligations
- Statutory or regulatory bodies - where required by law
7. International Data Transfers
Some of our providers process data outside the UK:
- Circle: please refer to Circle's privacy policy for transfer details
- Klaviyo: United States, under appropriate transfer mechanisms
- Zoom: United States, under Standard Contractual Clauses
- Anthropic (Claude): United States, under Standard Contractual Clauses
- Stripe: United States, under Standard Contractual Clauses
8. Data Retention
| Data type | Retention period |
|---|---|
| Community member data | For the duration of membership, plus 12 months after cancellation unless you request earlier deletion |
| Event attendance records | 3 years |
| Financial records | 6 years, in line with HMRC requirements |
| Email subscriber data | Until you unsubscribe, then deleted within 30 days |
| Contact form submissions | Deleted within 6 months of enquiry being resolved |
9. Safeguarding
The NICU Space is a community space for parents who have often been through significant trauma. We take safeguarding seriously.
If a member shares something that leads us to believe they or someone else may be at serious risk, we may need to share relevant information with appropriate services. We will always try to discuss this with you first unless doing so would put you or someone else at greater risk.
10. Automated Decision-Making
We do not use automated decision-making or profiling that produces significant effects on members. AI tools used by staff for administration do not make decisions about your membership or access to the community.
11. Your Rights
Under UK GDPR, 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 restriction: request that we limit how we use your data
- Right to object: object to processing based on legitimate interests
- Right to data portability: receive your data in a portable format
- Right to withdraw consent: where we rely on consent, you can withdraw it at any time
To exercise any of these rights, email hello@miraclemoon.co.uk. We will respond within one month.
12. Your Right to Complain
If you have concerns about how we handle your personal data, you have the right to complain to us directly. Email hello@miraclemoon.co.uk and we will acknowledge your complaint within 30 days, investigate, and respond to you.
You also have the right to complain to the Information Commissioner's Office (ICO) at any time:
- Website: ico.org.uk
- Telephone: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
13. Changes to This Policy
We may update this policy from time to time. The current version will always be available with the effective date shown at the top.