Neurocog Pty Ltd Privacy Policy

The Neurocog Pty Ltd Privacy Policy was updated on 1 August 2020.

Your privacy is important to Neurocog Pty Ltd so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal information.

You can review this information before enabling these features, in Settings related to those features and/or online at Neurocogsystem.com/privacy. Please take a moment to familiarize yourself with our privacy practices and contact us if you have any questions.

You may be asked to provide your personal information anytime you are in contact with Neurocog Pty Ltd. Neurocog Pty Ltd. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

What personal information we collect

When you create a Neurocog ID, we collect your email address, device identifiers, IP address, location information and data created by using the app.

How we use your personal information

Here are some examples of the types of personal information Neurocog Pty Ltd may collect and how we may use it:

- Location/Geographical Area                                                         

- Analyze where our app is being used.

- Email address                                                                                                            

- Communicate to you about the app.

- Text you enter to the app                                                                

- Update and improve the app, research.

- Values you enter to the app                                                          

- Update and improve the app, research.

We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which Neurocog Pty Ltd is subject, for the performance of a contract to which we are party, or for research purposes. If you have questions about this usage you can contact us at privacy@neurocogsystem.com.

We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Neurocog Pty Ltd ID account holders.

From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Neurocog Pty Ltd, you may not opt out of receiving these communications.

We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Neurocog Pty Ltd’s products, services, and customer communications.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

We may collect information such as unique device identifier, location, and the time zone where a Neurocog Pty Ltd product is used so that we can better understand customer behavior and improve our products, services, and advertising.

With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

 Cookies and Other Technologies

Neurocog Pty Ltd’s websites, and interactive applications, and email messages, may use "cookies" and other technologies. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Neurocog Pty Ltd also uses cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Neurocog Pty Ltd more convenient and personal.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Neurocog Pty Ltd may use this information in our marketing and advertising services.

Disclosure to Third Parties

At times Neurocog Pty Ltd may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help Neurocog Pty Ltd market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws. Neurocog Pty Ltd does not sell personal information, and personal information will never be shared with third parties for their marketing purposes.

Service Providers

Neurocog Pty Ltd shares personal information with companies who provide services such as information processing, managing data, providing customer service, and conducting research. These companies are obligated to protect your information and may be located wherever Neurocog Pty Ltd operates.

Others

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Neurocog Pty Ltd to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.  This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protection of Personal Information

Neurocog Pty Ltd takes the security of your personal information very seriously. Neurocog Pty Ltd the Neurocog App and the Neurocogsystem website protect your personal information during transit using encryption such as Transport Layer Security (TLS), previously known as Secure Socket Layer (SSL). When your personal data is stored by Neurocog Pty Ltd, we store it in encrypted form utilizing third-party storage.

When you use some Neurocog Pty Ltd products, services, or applications or post on a Neurocog Pty Ltd forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

The Existence of Automated Decision-Making, Including Profiling

Neurocog Pty Ltd does not use any social algorithms or profiling.

California

The California Consumer Privacy Act provides California consumers with the right to obtain from Neurocog Pty Ltd information about the personal information about you that we collect, use, and disclose. You can request this information by contacting privacy@neurocogsystem.com

If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from Neurocog Pty Ltd.

Nevada

You have the right to opt-out of the sale of your personal information. Neurocog Pty Ltd does not sell your personal information. You can request this information by contacting privacy@neurocogsystem.com

Children & Education

We understand the importance of taking extra precautions to protect the privacy and safety of children using Neurocog Pty Ltd products and services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own Neurocog IDs, unless their parent or guardian provided verifiable consent or as part of the child account creation process or they have obtained a managed Neurocog ID account (where available) through their school or school affiliated organization or company. A parent or guardian must review the Neurocog ID Disclosure and agree to the Consent to Neurocog Pty Ltd’s Collection, Use and Disclosure of the Child’s Information; and the Terms and Conditions, before they can create the Neurocog ID account for the child. In addition, schools that utilize Neurocog interactive applications or websites and have reviewed and consented to the Neurocog Pty Ltd Disclosures may create Neurocog IDs for students. The Neurocog IDs for Students handles student information in accordance with Neurocog Pty Ltd’s Privacy Policy. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with their account or the child’s Neurocog ID, they may contact at privacy@neurocogsystem.com.

Third‑Party Sites and Services

Neurocog Pty Ltd websites, products, applications, and services may contain links to third-party websites, products, and services.

Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

International Transfers

All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Personal information, relating to Neurocog Pty Ltd services, regarding individuals who reside in a member state of the European Economic Area, the United Kingdom and Switzerland is controlled by Neurocog Pty Ltd in Australia, and processed on its behalf by Neurocog Pty Ltd Inc. Neurocog Pty Ltd uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland.

Neurocog Pty Ltd abides by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. If you have an unresolved privacy or data use concern regarding our APEC CBPR and/or PRP certifications please contact us at privacy@neurocogsystem.com.

Our Companywide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to Neurocog Pty Ltd employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have any questions or concerns about Neurocog Pty Ltd’s Privacy Policy or data processing, you would like to contact us, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at privacy@neurocogsystem.com.

Mobile App

Get the Neurocog App

The Neurocog app is a self-help, mental well-being improvement app designed to be used standalone or in conjunction with professional sessions. The app features a range of scientifically-based exercises and a mood measure to help track your progress. For professionals the app can be integrated with your own procedures and will provide useful data on your client’s progress and feedback on your sessions.