1.1 We are committed to safeguarding the privacy of our website visitors and users. In this policy we explain how we will handle your personal data.
1.3 This website is owned and operated by Neurotech International Ltd.
1.5 Our data officer’s contact details are: email@example.com.
2. How we use your personal data
2.1 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services OR to obtain a better understanding of our website visitors.
2.2 We may process your account data (“account data“), which may include your name and email address, when provided to us after you have purchased our product and registered said product in our system. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR through the purchase of our product and agreeing to the Terms and Conditions as stipulated therein.
2.3 We may process[your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent OR the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
2.4 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include session data from the daily use of our product; the acquisition of EEG data from our device and the reports generated as a result of the data collection in each session. The service data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you and providing technical support as a result of the usage of our device by you. The legal basis for this processing is our legitimate interests, namely [the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract when you purchased the Mente Autism system.
2.6 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is your consent when submitting a form for more information from our website.
2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed[for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent.
2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.10 we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Disclosure of Personal Data
We may transfer your data to third-party service providers contracted to Neurotech, such as our worldwide distribution partners in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Neurotech’s data privacy procedures.
In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation, in order to protect your vital interests or the vital interests of another natural person.
4. International transfers of your personal data
We may transfer your data to third-party service providers contracted to Neurotech, such as our worldwide partners who are outside of the European Union, in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Neurotech’s procedures.
5. Retaining and deleting personal data
5.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.2 We will retain and delete your personal data as follows:
We will retain your data for the period during which you have signed up to use our Mente Autism system. The data we collect is a) required to register your product and b) to maintain a record of the treatment’s success or otherwise, spread over the period of usage.
A user’s data will be deleted, unless legally restricted from doing so due to other legislation that overrides the terms of the General Data Protection Regulation (GDPR), at a customer’s request in writing to firstname.lastname@example.org; or otherwise at the expiry of the period of time Neurotech is legally bound to store and keep data due to other legislation or regulations (eg. HIPAA). The customer is in his or her legal right to request a copy of all data retained about him or relative in a format that is readily accessible to the customer.
5.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained.
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7. Your rights
7.1 In terms of data protection legislation, you have the followings rights:
(a) the right to access;
This means that you have the right to ask us whether or not we process your data and if we do access to the personal data, together with certain additional information, i.e. the details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. This will be provided to you free of charge.
(b) the right to rectification;
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
(c) the right to erasure;
In some circumstances you have the right to the erasure of your personal data without undue delay.
(d) the right to restrict processing;
In some circumstances you have the right to restrict the processing of your personal data.
(e) the right to object to processing;
In some circumstances you have the right to object to processing of your personal data.
(f) the right to data portability;
In some circumstances you have the right to request a portable copy of your personal data.
(g) the right to complain to a supervisory authority; and
You have the right to submit a complaint with a supervisory authority responsible for data protection.
(h) the right to withdraw consent.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless
deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
to personalise your experience
to learn about your interests and preferences whilst visiting our site;
to enable us to improve and develop our website to cater for the needs of our visitors and customers, by noting and keeping track of website pages visited;
how frequently particular pages are visited to identify the most popular areas of our website.
to help us improve our customer service.
10. Cookies used by our service providers
11. Managing cookies
11.2 How to Turn Off Cookies. If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may impact your ability to use some of the functionality of this website.
11.3 You can learn more about cookies here: http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm
In the event that you have a complaint or a query about our data collection and data privacy policies, you have the right to contact Neurotech International Ltd directly by sending an email to email@example.com. You also have the right to lodge a complaint directly with your local Supervisory Authority. We are committed to processing all data requests within thirty (30) day from receipt. Each request will be acknowledged and action within the legal framework of the GDPR and any other legislation to which we are legal bound.