Privacy policy

Last Modified: 03/30/2023

Welcome to Vital Neuro. We are excited you have decided to use our solution to ‘Make The Shift’. While the details of our privacy policy are below, upfront we think it’s important that you understand the following:

• We don’t sell or share personally identifiable data. While the details of our policy are set forth below, rest assured your name, email address and EEG activity are ONLY used to help us improve the services and answer questions you may have about your use of our tools and the system.
• If you are affiliated and/or accessing this system through your employer or similar aggregator (For example, a school) – We promise not to share your PII or individual results with such an aggregator. We will only share de-identified and/or aggregated information relating your use of the system.
• We, as Vital Neuro employees, are also users of the same exact system. As such, we attempt to follows best practices in securing and protecting all data running through our system

We appreciate your trust –enjoy making ‘the shift happen.’

Now on to what our lawyers made us write / the actual privacy policy:​ 

1. INTRODUCTION.

Vital Neuro ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes: 

The types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the Vital Neuro Mobile Application (the "App").
Our practices for collecting, using, maintaining, protecting, and disclosing that information. 

This policy applies only to information we collect in this App, and in email, text, and other electronic communications sent through or in connection with this App. 

This policy DOES NOT apply to information that:​ 

• We collect offline or on any other Company apps or websites, including websites you may access through this App.
• You provide to or is collected by any third party (see Third Party Information Collection). 

Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

2.  CHILDREN UNDER THE AGE OF 13.

The App is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us support@vitalneuro.com.

3 .  INFORMATION WE COLLECT AND HOW WE COLLECT IT.

We collect information from and about users of our App:

• Directly from you when you provide it to us.
• Automatically when you use the App.
• If licensed via an employer, information your employer may provide us

Information You Provide to Us

When you download, register with, or use this App, we may ask you provide information:

• By which you may be personally identified, such as name, postal address, email address, telephone number ("personal information").
• That is about you but individually does not identify you, such as employer, gender, age,  date of birth, or your physiological data collected through a health tracker you elect to share with us. 

This information includes:

Information that you provide by filling in forms in the App or associated websites. This includes information provided at the time of registering to use the App, subscribing to our service or provided by a third party who procured a license for you. We may also ask you for information when you report a problem with the App.

• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research and business related purposes (“Survey Data”).
• Details of transactions you carry out through the App including EEG data and if applicable, of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.

You may also provide information for publication or display ("Posted") on public areas of the app or websites you access through the App/website (collectively, "User Contributions"). Your User Contributions are Posted and transmitted to others at your own risk. please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

We will retain the Survey Data until it is no longer useful for purposes of our solution. You may elect to have your personal or Survey Data deleted by contacting us. If feasible, we will remove your Survey Data from the data set upon your request. Please note that even if you have your personal information removed, all other data, in anonymized form, will still be retained.

Automatic Information Collection

When you download, access, and use the App, it may use technology to automatically collect:

• Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, logs, and IP address communication data and the resources that you access and use on or through the App.
• Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, and mobile network information.
• Stored Information and Files. The App, if authorized, also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location Information. This App does not collect real-time information about the location of your device.

If you do not want us to collect this information do not download the App or delete it from your device. 

Information Collection Technologies

The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting, you may be unable to access certain parts of our App.
• Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Analytics companies.
• Your mobile device manufacturer.
• Your mobile service provider.

They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. We may ask you to complete a survey in connection with your experience with the App using a third party tool. Participation in surveys is voluntary. You acknowledge that these third parties may collect information about and your device in connection with the App.

4.  HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the App and its contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Give you notices about your account/subscription, including expiration and renewal notices.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
• Provide customer service

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our App according to your individual interests.
• Recognize you when you use the App.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. In addition, we may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Vital Neuro's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Vital Neuro about our App users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website or App, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the App EULA, and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Vital Neuro, our customers or others. 

5. YOUR CHOICES ABOUT OUR COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
• Promotion by the Company. If you do not want us to use your email address to promote our own or third parties' products or services, you can opt-out by emailing support@vitalneuro.com.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website 

6.  YOUR STATE PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@vitalneuro.com.

7.  DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. 

8.  CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page, and, if required by applicable law, notify you. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes. 

9.  CONTACT INFORMATION 

To ask questions or comment about this privacy policy and our privacy practices, contact us at: 263 West End Ave, Suite 1D, NY, NY 10023 or at  support@vitalneuro.com.