Privacy Policy

Your privacy is important to Neeuro Pte. Ltd. (“Neeuro”, “we”, “us”, or “our”), a company registered in Singapore, Co. Registration No: 201302274H (“Neeuro”) and we are committed to protect the privacy of our users.

This Privacy Policy applies to all Neeuro products, mobile applications, warranty registration, services, programs, and websites, including the Neeuro SenzeBand (in all its models) and associated mobile software, the Neeuro Enterprise portal, and Neeuro website located at www.neeuro.com (individually a Product and collectively Products) you choose to access or participate in. This privacy policy is intended to explain how such information may and may not be collected, stored, processed, transferred, disclosed and utilized.

By continuing to use our products and services, you are deemed to have consented to the terms of this Privacy policy. If you do not want Neeuro to collect, use, store, transmit or display collected data, please do not install or use the Licensed Application.

This privacy policy describes how Neeuro manages Personal Data in compliance with the Singapore Personal Data Protection Act 2012 (No. 26 of 2012)(“Act”).

1. INFORMATION WE COLLECT

Neeuro collects personal data about you when you: (i) register for an account on our applications, (ii) use our products, (iii) sign up for our newsletter, (iv) online purchase, (v) communicates with us, or/and (vi) Neeuro’s programs. The personal data we collect consists of the following:

  • Registration and Contact Information
    1. Account registration with us will prompt you to provide us with information such as your login credentials (e.g. your name, email address and/or password), gender, birth month, birth year, geographic region, and level of education.
    2. Product warranty registration will collect information such as your full name, email address, street address including city, state/region and country.
    3. Customer service telephone calls, emails and other communications with us, may collect information like full name, email address or/and phone number, the date and time of the call or email, geographic region, and the subject and resolution of the issue.
  • Information Collected When Using Our Products

    Using our products will allow us to collect, store and use EEG data that include raw recordings, scores or performance data that are generated for you as part of your engagement with Neeuro’s Services.

    Our products (Neeuro SenzeBand and SDK) are also made available to third-party developers for incorporation into new games and applications, the EEG data collected, stored and used by third-party developers will not be accessible to Neeuro and shall not be covered by this Privacy Policy. Please refer to the third-party developers' privacy policy on their website to learn how are your EEG data used.

  • Payment Information

    Payments made through or for our product are processed through a third party payment processor, information to administer, manage, and fulfil the purchases you make may be collected by us or on our behalf. Such information may include payment information credit card number, account authentication information and contact information like your full name, billing and shipping address and email address.

  • Partners

    We received personal data about you when you use the services of our business partners, such as companies featured on our News page.

  • Neeuro’s Programmes

    We collect and store your personal data (e.g. name, birth month, birth year, gender, highest education level and geographic region) when you participate in Neeuro’s programmes conducted by us and our collaborators.

  • Log Data

    We automatically collect information on the statistical data from the applications or services that you use or engage in.

2. HOW WE USE YOUR INFORMATION

Neeuro collects personal data for some or all of the following reasons:

  • Provide and Maintain the Services
    1. as a unique identifier, used for accessing Neeuro’s Licensed Applications and Services.
    2. to process and fulfil your orders, send you confirmation emails for your order status and shipment, send you products you order, and allow you to pay for products you order.
    3. to provide customer with aftersales services, including warranty services.
  • Improve, Personalise, and Develop the Service
    1. make an inference and show you customized insights to help you maintain or improve your cognition.
    2. perform data analysis and testing.
    3. collect feedback to help improve our programmes, features or/and services.
    4. produce certification.
    5. enhance the online experience of using our website as further describe in section 6 (“Use of Cookies”).
  • Communicate with You
    1. to alert you about products upgrades and revisions.
    2. to send you newsletters, promotional information, respond to you when you contact us, and promote new features or products that we feel may be of interest you.
    3. to assist in addressing your inquiries and troubleshooting, about our products and services.
    4. to notify you about changes to our Services and provide you with information that is relevant to your use of Services.
3. DISCLOSURE TO THIRD PARTY

We do not sell, trade or otherwise transfer to third parties your personally identifiable information. This does not include authorised third parties who assist us in operating our website, applications, conducting our business or servicing you (credit card payments, delivering packages, online support), as long as these parties agree to keep this information confidential.

4. LINKS TO OTHER SITES

The website may contain links to other websites and microsites, whose privacy practices may differ from those of Neeuro. If you submit personal data to any of those sites, your personal data is not subject to this privacy policy. Links can be from content providers or/and partners who may use our logo or/and style as a result of a co-branding agreement yet they may still not follow the same policies as this privacy policy with respect to collection of your personal data.

Some parts of our applications may include social media features. These social media features are either hosted by a third party or hosted directly on our application. By using these features, you acknowledge that some information, including personal data, will be transmitted to us or may be shared with third-parties services. Your interactions with these features are governed by the privacy policy of the company providing them.

In general, once personal data is shared or disclosed, can be difficult to contain or retrieve. Neeuro will have no responsibility or liability for any consequences that may result because you have released and shared personal data with others.

We encourage you to read these third parties’ privacy policies to find out how they collect and process your personal data before you submit any personal data to them. By clicking on such links and leaving the website, we can no longer exercise control over any information you give to any other entity after leaving our website. Any access to such other sites or pages is therefore entirely at your own risk.

5. KEEPING YOUR ACCOUNT SECURE

Where Neeuro have given you (or where you have chosen) a password, which enables you to access parts of the products, applications and services, you are responsible for keeping this password confidential and be responsible for any misuse of such information. You must change your password regularly and must not share it with anyone. You are solely responsible for the security and confidentiality of your account.

6. USE OF COOKIES

Cookies are small files that may be stored automatically on our web browser that can be retrieved by our website. We may use cookies on our websites to help you personalise or enhance the functionality of our website, or to analyse visitor traffic for marketing or other purposes. Cookies can make our website more useful by storing information about your preferences, thus enabling us to improve our website. The information that we collect using cookies is non-personal information. Most web browsers are initially set to accept cookies. You are always free to decline our cookies if your browser permits, but please note that some parts of our websites may be designed to work using cookies and not work properly for you if you do so.

7. YOUR RIGHTS

Neeuro is committed to compliance with the different practices of personal data protection in different geographic regions (e.g, “GDPR” for EU residents, “PIPL” for China residents, “PDPA” for Singapore residents, and others). Thus, Neeuro gives the following rights at any point while we are in possession of or processing your personal data.

  1. Right of Inform – we have published this Privacy Policy to keep you informed as to what we do with your personal data. We strive to be transparent about how we use your personal data.
  2. Right of Access – you have the right to request a copy of the information we hold about you.
  3. Right of Rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. All the personal data that Neeuro’s applications have collected from you is listed on your “Account” page. You can make changes to your account information yourself by editing from within your account settings. Any changes you make to the information on the “Account” page will be effective immediately, and any electronic copies of the previous information will be automatically deleted from Neeuro’s records. You can make a request for rectification for all personal data that have been collected from you through Neeuro's webpage by writing to support@neeuro.com.
  4. Right to Erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  5. Right to Restriction of Processing – you have a right to ask us to restrict how we process your personal data. This means we are permitted to store the data but not further process it.
  6. Right of Portability – you have the right to have the data we hold about you transferred to another organisation in a safe and secure way.
  7. Right to Object – you have the right to object to certain types of processing such as direct marketing. All emails and newsletters from this site allow you to opt out of further mailings as further described section 8 (“Request to Withdraw Consent”).
  8. Right to Object to Automated Processing, Including Profiling – you also have the right not to have a computer make decisions about you directly (this doesn’t include general marketing based on your age or gender).

    To the extent that personal data collected is subject to the European Union’s GDPR, we ask for your explicit consent to process the data. We want to help you review and update your information to ensure it is accurate and up-to-date. Hence, any requests to exercise your rights can be directed to us through the contact details provided in this statement. Please note that we may require further information from you to verify your identity as well as the nature of your request before we proceed with your request. These requests can be exercised free of charge and will be responded by us within 30 days.
8. REQUEST TO WITHDRAW CONSENT

Should you wish to withdraw your consent to Neeuro’s use of your personal data, please stop using our products and services immediately and write to notify us that you wish for us to stop collecting, using or sharing your personal data and we will process your request within a reasonable time from such a request. Please ensure that your notification contains sufficient and specific information to enable us to comply with your request.

To unsubscribe from e.g. newsletters or marketing emails you will be able to do so via the “Unsubscribe” link in our email. If you wish to opt out at a later date, or if you rather not receive this information, Neeuro will provide an automated facility to do so, or if you prefer please send an email to support@neeuro.com.

9. DATA STORAGE AND RETENTION

We will process and store your personal data on our systems for as long as necessary by the purpose they have been collected for, in accordance with our retention policy. Retention periods will be determined to take into account the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorizes use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. After this time, your personal data will either be securely deleted or anonymised (so that it can no longer be associated with you) so that it can be used for analytical purposes.

10. CHILDREN’S PRIVACY

Neeuro mobile applications and programs are appropriate for children’s use, including those who are below 14 years of age (based on the definition in Singapore’s Children and Young Persons Act (Cap. 38)) or equivalent age specified by law in your jurisdiction. Neeuro is committed to respecting children’s privacy. For that reason, we encourage the child’s account to be created by their parent or legal guardian (“Parent”) or the child to seek the consent of Parent before registering for it. When Neeuro product is used by a school in an educational setting, we rely on the school to provide the requisite consent, on behalf of the Parent for Neeuro to collect information from a school user.

The child’s information that we collect and how we use these are described below:
(a) Collection of the child’s email address, name, gender, birth month and year, password, country, and level of education for use during child’s registration process and in account configuration to create and maintain the child’s account.

(b) Using our products will allow us to collect, store and use EEG data that include raw recordings, scores or performance data that are generated for you as part of your engagement with Neeuro’s Services.

We will not disclose the child’s information to any third party nor use it for other purpose unless the account has expressly opted-in to marketing emails.

As a small company, we do not have the resources to verify and track parental consent. Hence, if you are a child below the age to which you can provide consent in your country, please obtain a parental consent before registering an account on our mobile/tablet applications. Parents may review, update, or delete any of their children’s personal information that we may have collected by referring to section 8 to learn how to request to withdraw consent. The data storage and retention period for children is the same as described in section 9.

11. SECURITY

We value your privacy and are committed to protect the information we receive from you. The personal data we collect about you is kept secure from unauthorized access, use or disclosure. Only authorized employees have access to this information.

No security measures are 100% effective and Neeuro cannot warrant that your information will be absolutely secure. Any transmission of data on or through the use of Neeuro site is therefore at your own risk.

We will notify you of any data breach where your personal data has been obtained by unauthorised third parties, as required by law.

12. GOVERNING LAW

This privacy policy will be governed by and construed in accordance with the laws of Singapore, and the courts of Singapore will have non-exclusive jurisdiction over any claim or dispute arising under or in connection with this privacy policy.

13. UPDATES TO OUR PRIVACY POLICY

Neeuro will occasionally modify this Privacy Policy and any changes made to it in the future will be posted on this page, and where appropriate, notified on our homepage. Your continued use of one of Neeuro’s products or any related service or support following any such notification of changes will mean that you acknowledge and agree to the revised Privacy Notice.

14. CONTACTING US

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions or concerns regarding privacy related to the Service, please contact our DPO using the contact information set forth below, and we will try to resolve your concerns.

Attn: The Data Protection Officer
Neeuro Pte. Ltd. (Reg: 201302274H)
100H Pasir Panjang Road
#04-03
OC @ Pasir Panjang
Singapore 118524
Email: support@neeuro.com

Last Updated: 26 September 2022