Effective Date: 1 January 2020
NeuroGym® ("we" or "us" or "NeuroGym") has established this Privacy Policy to explain how it protects and manages the personal information that it collects from you online.
1. Consent for Collection, Use and Disclosure. Your use of the www.MyNeuroGym.com website ("Website") and/or your registration for Website products and services constitutes your consent to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Website or services.
We may occasionally update this Privacy Policy. When it is updated, we will also revise the "Effective Date" date at the top of this Privacy Policy. NeuroGym may make new uses or disclosures of information collected from users, such as in connection with an investigation of a breach of an agreement, contravention of laws, an emergency where the life, health, or security of an individual is threatened, the collection of a debt or in compliance with the request of a law enforcement agency or a court order, and in such circumstances, this Website will not inform and obtain the consent of the user prior to such change.
A user may withdraw his or her consent for collection, use, and disclosure at any time by sending an email to support @myneurogym.com. Please note that if the user decides to unsubscribe, this Website may suspend its provision of products and services to the user.
2. Accountability. NeuroGym collects certain "personal information" (information that personally identifies you) which may include, but is not limited to, your name, email address, PayPal email address, home or work address, telephone number, telephone call recordings, sign up source, date of account creation, date of account updates, time stamp, email open clicks, user ID, Facebook ID, country, language, time zone, login history, order details, information about your computer hardware and software (e.g., IP address, operating system, browser type, domain name, URL, access times, and referring website addresses), billing address, Masked Credit Card Information (for refunds), your rating of our support, other responses to surveys and questionnaires from our users during online registration and online purchasing. This information is provided to us by, you, the user.
When you participate, or apply to NeuroGym Events, some of the information we may collect about you and store in connection with the provision and fulfillment of our services to you may include: age, gender, marital status, religion, income range, education, profession, parent status, birthday, telephone number, education, user behavior, location, photo, testimonials with your authorization, or anonymized Facebook comments.
We have implemented this Privacy Policy to protect personal information received from its users, and to respond to any inquiries. The Privacy Policy also provides that we will use appropriate contractual means to establish a comparable level of protection for personal information which is sent for processing by third parties on our behalf.
NeuroGym has designated responsibility for your personal information to its Director of Operations, who ensures compliance with the principles in this Privacy Policy. Other NeuroGym individuals may be delegated to act on behalf of the Director of Operations.
3. Purposes for Collecting and Using Personal Information. NeuroGym collects and uses personal information for the following Identified Purposes:
(a) to understand user needs regarding Website services;
(b) to develop and provide our website and our products and services for our users;
(c) to fulfill your requests for products, services or information;
(d) to communicate with users and Website visitors, when necessary, and to inform users of upgrades, as well as of other products and services available from NeuroGym, its affiliates and third parties;
(e) to allow users to access limited-entry areas of the Website;
(f) to personalize some of our services and products for you and to deliver targeted advertisements and offers from the Website and third parties;
(g) to bill accounts and maintain payment records;
(h) to comply with any applicable law, regulation, legal process or government request;
(i) to respond to a legitimate claim, or to address our reasonable belief, that you are violating the rights of any third party or any of the agreements or policies that govern your use of the Website or any product or service on the Website;
(j) to protect the services, products, information, or rights of the Website, including but not limited to the security or integrity of the Website; and
(k) to identify and resolve technical problems concerning the Website, its information, products and services.
(l) to operate, improve, or promote our Service
(m) to respond to your email inquiries.
(n) to monitor and analyze trends such as: sales reports, behavior on the Website, email clicks and opens
(o) to market our products and services through: email marketing, advertising, including retargeting via Google and Facebook,
(p) purchase history
(q) To provide users with relevant special offers that will be sent from our trusted partners.
The Website also uses personal information in an aggregate form (i.e., not individually attributable to you) for its business analysis, operational, marketing, and other promotional purposes.
As advertisers on Facebook and through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.
We abide by Facebook’s Data Use Restrictions.
Any ad data collected, received, or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.
We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:
Remarketing with Google Analytics
Google Display Network Impression Reporting
DoubleClick Platform integrations
Google Analytics Demographics and Interest Reporting
By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookies) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Website. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Website, and match the right audience with the right advertising message.
You can opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.
If we hire other companies to provide some products or services on our behalf, then we will only provide those companies the personal information they need for the Identified Purposes, and we will limit their rights to use and further disclose your personal information as appropriate in the course of their work for us.
4. Limiting the Collection of Personal Information. NeuroGym limits its collection of personal information to only that information which is necessary for the Identified Purposes.
NeuroGym does not direct its Website to, nor does it knowingly collect any personal information from children under the age of thirteen and have adopted techniques to ensure compliance with this Privacy Policy and the Children’s Online Privacy Protection Act of 1998 ("COPPA"). COPPA and its accompanying regulations under United States federal law protect the privacy of children using the Internet.
Our Website includes content that may be unsuitable for children under thirteen and which are not necessarily monitored. We encourage all parents to talk to their children about online safety and to monitor their children’s use of the Internet.
5. Information Collected Automatically. NeuroGym uses "cookies" to obtain certain types of non-personally identifiable information, such as the Internet Protocol and referring website addresses, browser type and domain name, when a web browser accesses our Website or advertisements and other content served by us or on our behalf on other websites.
We and our partners use various technologies to collect and store non-personally identifiable information and anonymous data when you visit our pages, and this may include using cookies, web beacons or similar technologies to identify your browser or device. If you do not want to allow this level of tracking you can set up rules to manage cookies in your web browser or use incognito mode.
If you choose to not have your browser accept cookies from the Website, you may not be able to view all the text on the screens, or to experience a personalized visit, or to subscribe to certain service and product offerings on the Website. For more information on how to opt-out of cookie tracking please visit AboutAds.info (http://www.aboutads.info/choices/).
6. Disclosure, Processing, and Retention. We do not sell, rent, or disclose your personal information to anyone else, except:
(a) to someone you have designated to act as your agent, for one or more of the Identified Purposes (listed in Section 3, above);
(b) to NeuroGym's employees, independent contractors, subsidiaries, joint venturers, affiliates, consultants, business associates, service providers, suppliers and agents, acting on our behalf for any of the Identified Purposes;
(c) as necessary if NeuroGym has reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with NeuroGym' rights or property, other users of the Website, products or services, or anyone else that could be harmed by such activities see Terms of Use; and
(d) to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
In addition, as we continue to develop our business, we or our affiliates may sell or buy other businesses or entities, or we may merge with another company. In such transactions, personal information may be one of the transferred business assets. Also, in the event that NeuroGym or substantially all of its assets are acquired, your personal information may be one of the transferred assets.
Your information may be stored and processed in the United States, or in any other country in which NeuroGym or its affiliates, subsidiaries, or agents maintain facilities. By using this Website, you consent to any such transfer of information outside of your country.
The General Data Privacy Regulation (GDPR) takes effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.
As a company that markets its Website, content, products and/or services online, we do not specifically target our marketing to the EU. If the data you provide to us in the course of your use of our Website, content, products, and/or services is governed by GDPR, we will abide by the relevant portions of the Regulation.
If you are a resident of the European Economic Area (EEA), or are accessing this Website from within the EEA, you may have the right to request: access to, correction of, deletion of; portability of; and restriction or objection to processing of your personal data, from us. This includes the “right to be forgotten.”
To make any of these requests, please contact our GDPR contact at info@myneurogym.com.
7. Accuracy of Personal Information. We will use reasonable efforts to keep personal information accurate for the Identified Purposes, and for minimizing the possibility of making inappropriate user decisions based on such information. Users are responsible for informing NeuroGym about changes to their personal information. NeuroGym will use new or updated personal information it receives from users to update its own records.
8. Security Safeguards. NeuroGym will use commercially reasonable efforts to protect user's personal information.
9. Access to Personal Information. NeuroGym will afford you a reasonable opportunity to review the personal information in your file only, upon request to the Director of Operations at info@myneurogym.com or by writing to:
NeuroGym
PO BOX 5005, #138
Rancho Santa Fe, CA 92067
If NeuroGym is not able to provide access to some aspect of a user's personal information, it will provide reasons for denying access such as: that by doing so would likely reveal personal information about a third party, or that it is confidential commercial information or attorney-client privileged communications, or that the information relates to a breach of an agreement or a contravention of law, or that its disclosure could reasonably be expected to threaten the life or security of another individual.
Users have the right to request that inaccurate or incomplete information be amended as appropriate, by contacting NeuroGym at info@myneurogym.com. NeuroGym will promptly correct such personal information.