Neuropix Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, Neuropix Company Ltd. (“Neuropix”, “we”, “our”, or, “us”) use Personal Information (defined below) that we collect, receive and store pertaining to you (“User”, “you”) in connection with the following use cases:



(i) When you make use of the Neuropix App, mobile software application, and any other mobile software application, that we license alone or with our partners (each individually, and collectively, the “App”).

a. When you sign up for an account

b. When you purchase a product and/or the Services

c. When you make use of the Services through the App and devices we sell

d. When you use the App in demo mode (not combined with the devices)

(ii) When you make use of, or interact with, our websites: www.neuropix.co; www.neuro-pix.com; www.neuropix.co.uk; www.neuropix.asia (“Website”)

a. When we process your job application(s)

b. When you contact us (e.g. customer support or request for information)

(iii) Other

a. When you attend a marketing event and provide your Personal Information

b. When you exchange business cards with us

c. When we acquire your Personal Information from third-party sources (such as lead-generation companies)

d. When we use the Personal Information of our service providers or partners

e. When we use the Personal Information of our customers  

f. When you interact with us on our social media profiles (e.g. Facebook, Instagram, Twitter, LinkedIn)

Table of Contents

  1. Introduction
  2. Terms of use and EULA
  3. What information we collect, why we collect it, and how it is used
  4. Period of storage of collected information
  5. How we protect and store your information
  6. How we share your personal information
  7. Additional information regarding transfers of personal information
  8. How can I delete my account?
  9. Links to and interaction with third party products
  10. Log files
  11. Google analytics
  12. Access/ Accuracy
  13. Contact us


1.INTRODUCTION


The website and/or any App offered are individually and collectively referred to herein as the “Services”.

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to recognized cybersecurity standards. Please read this Privacy Policy carefully, so that you can fully understand our practices in relation to Personal Information. “Personal Information” means any information that can be used, alone or together with other information, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions.

You are not legally obliged to provide us Personal Information and providing us Personal Information is at your own free will. To the maximum extent permitted by law, by using the Services, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein.

We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site, and your continued use of the Services thereafter means that you accept those changes.

As the controller, we have technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.



2. TERMS OF USE AND EULA


This Privacy Policy forms part of our Terms of Use which are available at https://neuro-pix.com/privacy-policy (“Terms”) and the App’s End User License Agreement which can be viewed from within the App and which you accept prior to downloading, installing and/or using the App for the first time (“EULA”).



3. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED


When you make use of the App, mobile software applications, and other mobile software application, that we licence

When you sign up for an account

Information we collect:

  • Full name
  • Email address
  • User and password
  • Any other information you decide to provide/supply


Why is the Information collected and for what purposes?

  • To create an account
  • To contact you in connection with the Services/products that you have registered for


Third parties with whom we share your information

3rd party platforms such as for the following purposes:

  • Microsoft Office
  • Facebook (Custom audience and Lookalike Audience) – we share your email address (hashed) with Facebook in order to create ‘custom audiences’ based on your information publicly available on Facebook and deliver advertisements to people who have similar characteristics to people on your custom audience list

Consequences of not providing the information

  • Cannot create or maintain an account
  • Cannot contact you in connection with the Services/products that you have registered for

When you purchase a product and/or services

Information we collect:

  • Full name
  • Email address
  • Billing information
  • Any other information you decide to provide/supply

Why is the Information collected and for what purposes?

  • To process the order of the product
  • To perform/execute the agreement
  • To contact you in connection with the Services/products that you have purchased

Third parties with whom we share your information

3rd party platforms such as for the following purposes:

  • Microsoft Office
  • Facebook (Custom audience and Lookalike Audience) – we share your email address (hashed) with Facebook in order to create ‘custom audiences’ based on your information publicly available on Facebook and deliver advertisements to people who have similar characteristics to people on your custom audience list

Consequences of not providing the information

  • Cannot process the product order
  • Cannot perform the agreement
  • Cannot contact you in connection with the Services/products that you have purchased

When you make use of our Services through the App or Device

Information we collect:

  • Full name
  • Email address
  • Geolocation
  • Weather conditions at the location
  • Information regarding disease episodes (optional via user input; related symptoms; pain level; presence of nausea; presence of aura (interference with vision), presence of phonophobia (sensitivity to sound), presence of photophobia (sensitivity to light), on which side of the head did the pain appear
  • Your smartphone’s model and version of the OS
  • Any other information you decide to provide/supply


Why is the Information collected and for what purposes?

  • To make use of the App
  • To register and/or record your disease episodes
  • To keep track of the disease diary


Third parties with whom we share your information

  • None. All data is stored locally on the phone.


Consequences of not providing the information

  • Cannot make use of the Service
  • Cannot register and/or record your disease episodes
  • Cannot keep track of a disease diary
  • Cannot control and program the device
  • Cannot contact you in connection with the Services you use


When you make use of, or interact with, our website

Information we collect:

  • Full name
  • Geolocation
  • Email address
  • ISP address


Why is the Information collected and for what purposes?

  • To make use of the website

Third parties with whom we share your information

  • None


Consequences of not providing the information

  • Need to agree to the use of cookies


When you contact us (e.g. customer support)

Information we collect:

  • Full name
  • Email address
  • Message
  • Any other information you decide to provide/supply


Why is the Information collected and for what purposes?

  • To process and answer questions
  • To provide support (e.g. to solve problems)
  • To customize your experience
  • To send marketing communications


Third parties with whom we share your information


3rd party platforms such as for the following purposes:

  • Microsoft office
  • Facebook (Custom audience and Lookalike Audience) – we share your email address (hashed) with Facebook in order to create ‘custom audiences’ based on your information publicly available on Facebook and deliver advertisements to people who have similar characteristics to people on your custom audience list


Consequences of not providing the information

  • Cannot assist you and respond to your query
  • Cannot provide support
  • Cannot customize your experience
  • Cannot send you marketing communications


Other practices

When you attend a marketing event and provide Personal Information


Information we collect:

  • Full name
  • Email address
  • Company or institute of affiliation
  • Position or role
  • Any other information you decide to provide/supply


Why is the Information collected and for what purposes?

  • To establish a business connection
  • To send marketing communications


Third parties with whom we share your information

3rd party platforms such as for the following purposes:

  • Microsoft office


Consequences of not providing the information

  • Cannot establish a business connection
  • Cannot send you marketing communications


When you exchange business cards with us

Information we collect:

  • Full name
  • Email address
  • Company or institute of affiliation
  • Position or role
  • Any other information you decide to provide/supply


Why is the Information collected and for what purposes?

  • To establish a business connection
  • To send marketing communications


Third parties with whom we share your information

3rd party platforms such as for the following purposes:

  • Microsoft office


Consequences of not providing the information

  • Cannot send you marketing communications


When we acquire your Personal Information from third-party sources (such as lead-generation companies)


Information we collect:

  • Contact information


Why is the Information collected and for what purposes?

  • To establish a business connection/ discussion
  • To send marketing communications


Third parties with whom we share your information

3rd party platforms such as for the following purposes:

  • Microsoft office


Consequences of not providing the information

  • Cannot establish a business connection
  • Cannot send you marketing communications


When we use the Personal Information of our service providers

Information we collect:

  • Full name
  • Email address
  • Company or institute of affiliation
  • Position or role
  • Any other information you decide to provide/supply


Why is the Information collected and for what purposes?

  • To contact our service providers
  • To process the order of the service


Third parties with whom we share your information

3rd party platforms such as for the following purposes:

  • Microsoft office


Consequences of not providing the information

  • Cannot communicate with you
  • Cannot process the order of the service
  • Cannot perform the agreement


When we use the Personal Information of our customers

Information we collect:

  • Full name
  • Email address
  • Company or institute of affiliation
  • Position or role


Why is the Information collected and for what purposes?

  • To provide our products and services
  • To perform the applicable agreement
  • To communicate with our customers/clients


Third parties with whom we share your information

3rd party platforms such as for the following purposes:

  • Microsoft office
  • Facebook (Custom audience and Lookalike Audience) – we share your email address (hashed) with Facebook in order to create ‘custom audiences’ based on your information publicly available on Facebook and deliver advertisements to people who have similar characteristics to people on your custom audience list


Consequences of not providing the information

  • Cannot provide the services and/or our products

  • Cannot perform the agreement

  • Cannot communicate with you


When you interact with us on our social media profiles (e.g. Facebook, Instagram, Twitter, LinkedIn)


Information we collect:

  • Full name
  • Email address
  • Company or institute of affiliation
  • Position or role
  • Any other information you decide to provide/supply


Why is the Information collected and for what purposes?

  • To reply and/or respond to your request or question
  • To establish a business connection/discussion


Third parties with whom we share your information

3rd party platforms such as for the following purposes:

  • Microsoft office

Consequences of not providing the information

  • Cannot reply or respond to your request
  • Cannot establish a business connection



4. PERIOD OF STORAGE OF COLLECTED INFORMATION


Personal Information. Your Personal Information (as described above) will be stored until we no longer need the information and proactively delete it or you send us a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

Cookies. We use cookies and other tracking technologies to improve your browsing experience on our website, to analyse our website traffic, and to monitor how people use the website, aiming to improve the website and make it more useful. By browsing our website, you consent to our use of cookies and other tracking technologies. The period of storage and collected information depends on the cookie. You may also control and delete these cookies through your browser settings. Some cookies (e.g. essential cookies) cannot be disabled.



5. HOW WE PROTECT AND STORE YOUR INFORMATION

a. Security. We have appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

b. Retention of your Personal Information. In addition to the retention periods mentioned in Section 4 above, in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.



6. HOW WE SHARE YOUR PERSONAL INFORMATION


In addition to the recipients described above, we may share your information as follows:


  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.
  • Where you have provided your consent to us sharing the Personal information (e.g. where you provide us with marketing consents or opt-in to optional additional services or functionality); and
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.



7. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION


Where we transfer your Personal Information outside of our operating jurisdiction, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Information;


Some of these assurances are well recognized certification schemes like the EU-US Privacy Shield for the protection of Personal Information transferred from within the EU to the US; or


Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.



8. HOW CAN I DELETE MY ACCOUNT?


Should you ever decide to delete your Account, you may do so by emailing support@neuro-pix.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public, unless otherwise prohibited by law.



9. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS


The Website may enable you to interact with or contain links to your Third Party Account and other third party Websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.



10. LOG FILES


We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyse trends, administer the Website, track users’ movement around the Website, and gather demographic information.



11. GOOGLE ANALYTICS


The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at www.google.com/policies/privacy/. You may learn more about how Google collects and processes Information specifically in connection with Google Analytics at www.google.com/policies/privacy/partners. You may prevent your information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at http://tools.google.com/dlpage/gaoptout/.



12. ACCESS/ ACCURACY


To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to support@neuro-pix.com. Your email should include adequate details of your request.



13. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, or opt-out from use and disclosure of your personal data to Facebook, we encourage you to first contact us at support@neuro-pix.com.



Last Update: August 27th, 2022

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