This Privacy Policy was last updated on April 26, 2024.

FOREWORD

NeuroCare.AI understands and recognizes the paramount importance of having a well-defined and comprehensive Privacy & Cookie Policy for the success of our organization. Operating in an environment characterized by legal complexities and continual changes, we believe it is absolutely imperative that we proactively inform our users and thoroughly explain the procedures we use to process your personal information.

NeuroCare.AI deeply respects your right to privacy and is fully committed to protecting your personal data. This commitment is reflected in our Privacy & Cookie Policy, which has been designed to inform you on how we look after your personal data when you visit our website. It also explains your privacy rights and how the law protects your right to privacy.

This Privacy & Cookie Policy applies when you visit our website and when you utilize our other services, which include web chat communications. It’s important to note that this Privacy & Cookie Notice may be supplemented or replaced by additional privacy statements or terms provided to you from time to time.

WHAT THIS POLICY COVERS

Our Privacy & Cookie Policy is an evolving document, and we will continue to update it as necessary, in response to changes in law, technology, our data collection practices or for any other reason. We encourage you to review our Privacy & Cookie Policy regularly to stay informed about how we collect, use, and protect your personal information.

This Policy covers our collection, use and disclosure of information about identifiable individuals and information which can be used to identify an individual (“Personal Data”). Personal Data does not include “aggregate” information which we aggregate from information (including Personal Data) you provide to us. Personal Data may be collected about our customers, prospective customers, visitors to the Website, and end users of the Services. You can choose not to provide us with certain information, but by doing so, you may not be able to take advantage of many of the features and functionality of our Services.

You understand and agree that the Company and its authorized business partners, affiliates, subsidiaries or agents may collect, maintain, and process information provided by you, on and through the Services. You represent and warrant that you have permission to share any information you elect to provide to NeuroCare.AI, you consent to such information being shared with third parties as described in this Policy, and that such information is accurate, current, non-misleading, and consistent and relevant for the purpose for which you are providing information.

WHO ARE WE

NeuroCare.AI is an innovative company leveraging the latest technological advancements in artificial intelligence to significantly improve healthcare outcomes and increase productivity. Our primary mission is to revolutionize the healthcare industry by integrating cutting-edge AI technology into various medical practices and healthcare services.

• We are deeply committed to safeguarding the personal information of our customers, users, employees, and other stakeholders. Our robust security measures and data protection policies ensure the utmost protection of your personal data. At the same time, we strive to help our customers, employees, investors, and the broader society create a deeper impact and make informed decisions.
• We understand the importance of privacy and respect the individual’s right to control their personal information. If you have any questions or concerns about your privacy rights and how we handle your personal information, please feel free to reach out to us. You can contact us at [email protected].
• At NeuroCare.AI, we believe in transparency and openness. We want our users to understand how we collect, use, and protect their personal information. Therefore, we recommend that you read our privacy policy to get a better understanding of our data practices.

PERSONAL DATA THAT NEUROCARE.AI COLLECTS AND PURPOSE OF USE

The type of personal information that NeuroCare.AI collects largely depends on the nature of the relationship between us and the services we deliver to you. In consonance with the aforementioned, we may collect a variety of personal information about you, which includes but is not limited to:

• Name and contact information: This includes your first and last name, email address, postal address, and telephone number. We use this information to communicate with you and provide our services effectively.
• Work-related information: This includes details such as your job title, employer information, and other relevant employment or education information. We use this information to understand your professional background and tailor our services accordingly.
• Account Credentials: This includes your passwords and other security information used for authentication purposes and providing access to our services.
• Financial information: This includes details of your bank accounts, credit card numbers, and debit card numbers. This information is necessary for us to process payments for our services.
• Usage information: This refers to behavioral information about how you navigate within our services, which elements of our services you use the most, and information regarding the products and/or services you wish to order, wish list, preference, interest, etc. We use this data to improve our services and provide a more personalized user experience.
• Computer, device and connection information: This includes your IP address, browser type and version, and location. We use this information to ensure our services function properly on your device and to provide location-specific services.
• Audio and Visual Information: This includes your voice and image as captured in photographs, video, or audio recordings if you attend our events or leave us a message. We use this information to enhance our services and provide a more personalized user experience.
• Any other information shared by you through our website, apps, and other products and services including web chat communications. We use this information to understand your needs and preferences better and serve you more effectively.

In addition to the personal data collected directly from you, NeuroCare.AI may also process personal data collected indirectly, including via the Website:

• For any purposes specified in this Privacy & Cookie Policy and/or in our Terms of Use;
• To contact you as and when NeuroCare.AI believes it to be necessary for technical, administrative, or security reasons;
• To prevent, detect, and fight fraud, security threats, or other illegal or unauthorized activities;
• To ensure legal compliance with legal requirements that apply to us and you;
• To ensure compliance with the Terms of Use that apply to us and you;
• For the purposes described in the sections titled as “Sharing Information with Third Parties” and “Cookies”.

By providing any personal data to NeuroCare.AI, you warrant and represent that the information you provide is complete, accurate, and correct. Your failure to do so will likely result in NeuroCare.AI being unable to contact you about your inquiries or provide you with our services. It is your responsibility to update us if any of the information you provided is no longer accurate or correct and inform us immediately of the required updates.

OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

NeuroCare.AI respects the legal requirements for processing personal data and only processes your personal data where we have a legal basis to do so. The following are the legal bases under which we process your information in the manner specified by the law:

• As permitted by applicable law: We may process your personal information when it is necessary for the performance of a contract, the compliance with a legal obligation, or other situations where processing is permitted by applicable law.
• Legal obligation: We may process your personal information when necessary to comply with a legal obligation that is binding on NeuroCare.AI (not including contractual obligations).
• Performance of a contract: We may process your personal information when it is necessary for the performance of a contract to which NeuroCare.AI and you are parties.
• Legitimate interests: We may use your personal information where we have legitimate interests to do so. For instance, we analyze a user’s behavior on our Website to continuously improve it, and we process information for administrative, fraud detection, and other legal purposes.
• Consent: Where no other legal basis for processing applies, we may process your personal information based on your consent, which you will be asked to provide from time to time.

HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information from the following sources:

• Direct interactions, such as when you register for our services, make a purchase, or communicate with us, including through our web chat features.
• Data from Third Parties, such as information on third-party websites or other information you may have made publicly available, or information provided by third party sources.
• Automated tracking technologies, such as information automatically collected about your interactions with our services and websites using various technologies such as cookies, web logs and beacons and internet tags.

JOINT CONTROLLERSHIP

At present, NeuroCare.AI does not have any arrangement where it jointly determines the purpose and means of processing the personal data collected from the Website with any third-party entity, also referred to as a “joint controller”. However, in the event that such a joint controllership situation arises in the future in relation to your personal data, we want to assure you that the essence of the legal relationship between NeuroCare.AI and such other controllers will be clearly communicated to you. This information shall be made available to you upon request to ensure utmost transparency regarding the handling and processing of your personal data.

SHARING OF INFORMATION WITH THIRD PARTIES

NeuroCare.AI is committed to safeguarding your privacy. We do not, and currently do not have any plans to share or sell any of your personal data to any third party. The transfer of your personal details or any information collected pertaining to your activities on the Website (provided that such details and information identify you personally) to any third party is something we avoid, except in certain specific cases or as otherwise outlined in this Privacy & Cookie Policy.

In certain circumstances, if NeuroCare.AI has reasonable grounds to believe that you have breached the Terms of Use, or performed any act or omission that NeuroCare.AI reasonably believes to be violating any applicable law, rules, or regulations, NeuroCare.AI may find it necessary to share your information. This could be with law enforcement and other competent authorities and with any third party that may consult NeuroCare.AI or assist in connection with any such breach. This would be required to handle any result of your wrongdoing. The information may be used to contain, remediate, prevent, investigate any such breach, and/or establish or exercise any of NeuroCare.AI’s legal rights.

In addition, your personal data may be disclosed in the following scenarios:

• As permitted or required by lawful requests by applicable local law enforcement agencies or regulatory authorities, or agencies with responsibility to oversee and enforce national security;
• In any case of dispute, or legal proceeding of any kind between you and us, or between you and other users or third parties;
• In any case where NeuroCare.AI may reasonably believe that sharing information is necessary to prevent serious damage to you or to your property or to any third party or their property;
• If NeuroCare.AI organizes the operation of the Website within a different framework, or through another legal structure or entity, or if NeuroCare.AI is acquired by, or merged with another entity. However, such entities would have to agree to be bound by the provisions of this Privacy & Cookie Policy; and
• NeuroCare.AI may share personal data with its Affiliates, for the purpose of assisting in the processing activities detailed herein or if such Affiliate is best suited to handle your enquiry.

NeuroCare.AI may share personal data with its service providers for the purpose of helping NeuroCare.AI execute certain tasks outsourced to them, or providing capabilities NeuroCare.AI requires. The service providers to whom we may provide personal data in connection with the personal data collected through the Website are: (1) email service providers for email campaigns management and to send you emails on our behalf, with the express provision that their use of such information must comply with our instructions; (2) recruiting services providers, in relation to activities on the Website related to submission and processing of CV and Job applications through the Website; (3) registration management of users to events through the website; (4) billing, processing payments, marketing automation, NeuroCare.AI advertisements on social media, CRM platform, analytics tool providers, web page building tools, cloud services, support and maintenance operation tools. Our service providers do not have any right to use your personal data collected from the Website beyond what is necessary for the purpose of facilitating their services for us, and are subject to data protection agreements to the extent required under applicable law.

Lastly, NeuroCare.AI is also entitled to transfer or share anonymous, statistic or aggregative information with companies or organizations connected to NeuroCare.AI, and with suppliers, business partners, advertisers, and every third party, according to NeuroCare.AI’s absolute discretion. This is usually for the purpose of improving our services and products.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION & OUR DATA RETENTION PRACTICES

Your personal information will be processed to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which the information is collected, in accordance with our data retention policies and the applicable data protection laws. Please note that our data retention policy may change depending on the Institutional Agreement, we may sign separately.

When we no longer need your personal information, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymise it so you can longer be identified from it.

We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.

Unless otherwise set forth in the applicable Terms of Use or a separate agreement with you governing the applicable Services, if you cease using such Service, we may retain or destroy, at our discretion, all Personal Data and non-personally identifiable information we collect through your use of such Service. All retained Personal Data will remain subject to the terms of this Policy (or an applicable Business Associate Agreement).

HOW WE PROTECT YOUR PERSONAL INFORMATION

We have put in place an internal framework of policies and minimum standards across all our businesses to keep your data safe. In addition, we limit access to personal information by our employees, business partners, service providers and third-party service providers to a “need-to-know” basis.

More specifically and in accordance with the law, we take appropriate technical and organizational measures (policies and procedures, IT security and others) to ensure the confidentiality and integrity of your personal information and the way it is processed.

SOCIAL MEDIA FEATURES

The Website includes social media plugins, including links to Facebook, LinkedIn and Twitter. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the plugin to function properly. Social media features are governed by the Privacy & Cookie Policy of the company providing it.

LINKS TO THIRD-PARTY SITES

This Website contains links to other sites that are not owned or controlled by NeuroCare.AI. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies only to information collected by this Website.

GLOBAL PROCESSING OF PERSONAL DATA OUTSIDE THE USA

Our Website may be operated from various locations around the globe, which may be different from your current location. This means that your personal data could potentially be accessed, processed, and transferred to and from these different countries. We take appropriate measures to ensure the security and privacy of your data during these processes. Here are the specific circumstances under which your data may be accessed or processed:

• Our affiliates under the NeuroCare.AI umbrella may access your data for operational, administrative, and compliance purposes, ensuring that we can provide you with the best possible service.
• Our sales teams, business partners, operational teams, and customer support teams across our various locations may also access your data. The specific locations of these teams are detailed on our Website, and they will only use your data to provide you with support, answer your queries, and improve our services.
• Our trusted service providers may also access your data, but only for the purposes we have specified above under the section titled “Sharing of Information with Third Parties”. These purposes primarily involve improving your experience with our services.

By consenting to the collection and use of your personal information, you are agreeing to your personal information being handled in this manner. This includes the collection, transfer, and storage of your data for the purposes specified. We appreciate your trust in us and assure you that we take your privacy seriously.

Safeguards

The safeguards we deploy for performing such transfers across boundaries:

• Adequacy – any transfer to NeuroCare.AI Affiliates may be made on the basis of an adequacy decision made by the European Commision.
• Model Clauses – with some of our processors, we use standard contractual approved by the European Commission that are binding standards of processing of personal data committed contractually by third parties processing information for us and on our behalf.
• Consent – in the absence of an adequacy decision or Model Clauses, and in the absence of any other right to transfer your data, your consent shall serve as the basis for such transfer. By accessing and using the Website, you agree and understand that your information may be transferred to the EAA, from the EAA or other countries in which you may be using or accessing the Website, to other jurisdictions outside your own location (including outside the EAA). The transfer will be to such third parties as described under “Sharing of Information with Third Parties”.

GDPR Disclosure

If you are a data subject located within the European Economic Area (EEA) or the United Kingdom, your personal data may be governed by the EU General Data Protection Regulation 2016/679 (“GDPR”) and the UK GDPR. In this context, you may be entitled to the following rights:

• Right to be informed: You have the right to be informed about how your personal data is being used and processed. This includes understanding the purposes of processing, the categories of personal data involved, and the recipients or categories of recipient to whom the personal data have been or will be disclosed.
• Right of access: You are entitled to access your personal data processed by us. This includes the right to obtain confirmation as to whether or not personal data concerning you is being processed. If that is the case, you have the right to access the personal data and the purposes of the processing, categories of personal data concerned, recipients or categories of recipient to whom the personal data have been or will be disclosed, and, where possible, the envisaged period for which the personal data will be stored.
• Right to rectification: If you find that we hold inaccurate personal data about you, you have the right to request its correction.
• Right to erasure: In certain circumstances, you have the right to request the deletion of your data. This is also known as the ‘right to be forgotten’.
• Right to restrict processing: You have the right to restrict the processing of your personal data in certain circumstances. This means that you can limit the way we use your data.
• Right to object: If the processing of your personal data is based on our legitimate interests, you have the right to object to these processing activities.
• Right to withdraw consent: If the processing of your personal data is based on your consent, you have the right to withdraw this consent at any time.
• Right to object to direct marketing: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: In certain circumstances, you have the right to request that we transfer or port elements of your data either to you or another service provider. This right applies if the processing is based on your consent and is made by automated means.
• Right to lodge a complaint: You have the right to file a complaint with your Supervisory Authority within the EEA, as prescribed by the GDPR.

You can exercise these rights to the extent that they apply to you by contacting NeuroCare.AI via the contact information provided. We commit to respond to your request within the applicable time frame prescribed by the law. In all cases, we will make every effort to respond within 30 days of receiving your request.

Please note that while NeuroCare.AI will make reasonable efforts to accommodate your requests, there may be circumstances where we may deem your request as being unfounded or not eligible under the applicable law. In such instances, NeuroCare.AI expressly reserves the right to refuse your request. To ensure the security of personal data, before NeuroCare.AI can act on any request, provide information, or correct any inaccuracies, we may need to verify your identity by requesting specific information or identification.

CCPA/CPRA DISCLOSURE

The following section is designed specifically for residents of California, intended to provide necessary information and disclosures in line with the California Consumer Privacy Act of 2018 (known in the text as “CCPA”). This law has been further amended by the California Privacy Rights Act (known in the text as “CPRA”).

In this section, certain terms have specific meanings, and these are aligned with the definitions provided by the CCPA and CPRA. These terms include, but are not limited to, “Business Purpose”, “Consumers”, “Personal Information”, and “Sale” (or “Sell”). It is essential to note that these terms are interpreted strictly in line with the CCPA and CPRA.

To ensure transparency, we have detailed the categories of Personal Information, including Sensitive Personal Information, that we have collected from Consumers. We have also disclosed this information for a business purpose over the past 12 months. For a more detailed breakdown of these categories, please refer to the table located at the top of this Privacy & Cookie Policy.

The categories are as follows:

1. Identifiers, which can include names and government identification numbers;
2. Personal information, as defined by the California safeguards law. This can include contact information and financial data;
3. Characteristics of protected classifications under California or federal law, such as gender and marital status;
4. Commercial Information, which can include transaction information and account details;
5. Internet or network activity information, which can include browsing history and interactions with our Website;
6. Geolocation data, which refers to data about your device location;
7. Audio, electronic, visual, thermal, olfactory, and similar information, which can include video, photography and call and video recordings;
8. Professional or employment-related information, which could include work history and information about former employers;
9. Education information, which could include information about your school and date of graduation; and
10. Inferences drawn from any of the Personal Information listed above to create a profile. This profile could include, for example, details about an individual’s preferences and characteristics.

The sources we have collected this Personal Information from are: directy from California residents or their representatives.

In the past 12 months, however, we have not “sold” Personal Information relating to California residents within the meaning of the CCPA and CPRA. For the purposes of this Privacy Notice, “sold” means the disclosure of Personal Information for monetary or other valuable consideration.

In the past 12 months, we have not used Personal Information relating to California residents within the meaning of the CCPA and CPRA for automated decision making and NeuroCare.AI does not sell or share your Personal Information to third-parties, or use or share your Personal Information for cross-contextual marketing.

If you are a California resident, you may also request that we delete or correct Personal Information that we collected from you.

Before NeuroCare.AI is able to accommodate any respond to any request, we may ask to verify your identity by providing us with certain information or identification. In some instances, we may decline to honour your request. For example, we may decline to honour your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. In other instances, we may decline to honour your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights, such as information relating to our employees and contractors that is used for our employment and vendor management purposes.

Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

CALIFORNIA AND DELAWARE “DO NOT TRACK” DISCLOSURES

California and Delaware law require us to indicate whether we honor  “Do Not Track” settings in your browser concerning targeted advertising. NeuroCare.AI adheres to the standards set forth in this Privacy & Cookie Policy and does not monitor or respond to Do Not Track browser requests.

CHILDREN’S PRIVACY

At NeuroCare.AI, we are committed to protecting the privacy of children. It is our policy not to knowingly collect personal data from individuals who are under the age of 16 through our Website without obtaining appropriate consent. This is in line with our commitment to comply with all applicable laws and regulations relating to the protection of minors.

If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information via the Website without his/her consent, it is strongly advised that they contact NeuroCare.AI immediately. We have procedures in place to handle such situations, including deleting the information from our files.

Moreover, if we become aware that a child under the age of 16 has provided us with personally identifiable information without appropriate consent, we will take immediate action. This includes deleting such information from our files and, where applicable, notifying the relevant authorities.

Our contact information is provided below for any queries or concerns relating to this policy.

VIDEO AND PHOTOGRAPHY

Please be aware that NeuroCare.AI will be taking photographs and video in public areas of any events you may register to through the Website (session rooms, exhibit halls, etc.). We may use such media in marketing materials, educational products and publications. Your image and the sound of your voice may be recorded. If you are identified during the recording, or identify yourself by name, that information may be included in our materials. Recordings may be edited, copied, exhibited, published or distributed.

Exclusions:

This Policy does not apply to any Personal Data collected by the Company other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to the Company through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and the Company shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

INTEREST BASED ADVERTISING

We engage in interest-based advertising and personalized content that we believe will be of interest to you. Advertisements, emails, and other messages may be delivered to you by NeuroCare.AI or its service providers based on your online or mobile behavior, your search activity, your geographic location or other information that is collected by us or obtained by such third parties using cookies (such as your clicking on our paid ads in Google or other social networks).

In addition, we and our business partners use third parties to establish deterministic or probabilistic connections among devices (such as smartphones, tablets, and computers) to deliver more relevant advertising to you and for advertising analytics and reporting purposes. This means that information about your use of websites or applications on your current device may be combined with information from your other devices. We also may share this information and other inferences with third parties to allow them to target advertising, personalize content, or analyze behavior. This allows, for example, advertisements you see on your tablet to be based on activities you engaged in your smartphone. These business partners may share and combine information from cookies with identifiers (such as device IDs assigned by Google or Apple) and IP addresses to make connections among related devices. This allows for a more personalized experience across the Website.

If you have any questions about our Privacy & Cookie Policy, you may contact us via the contact information listed below.

COOKIES

A cookie is a small text file that is stored in your web browser that allows NeuroCare.AI or a third party (such as NeuroCare.AI third party service providers) to recognise you. Cookies might be used for the following purposes:

1. To enable certain functions;
2. To provide analytics;
3. To store your preferences; and
4. to enable ad delivery and behavioral advertising.

Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years. Cookies placed by the website you’re visiting are sometimes called “first party cookies”, while cookies placed by other companies are sometimes called “third party cookies.”

When you access and/or use the Website, NeuroCare.AI or a third party may place a number of cookies in your browser. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used.

Each cookie serves one of four different purposes:

• Strict Necessary Cookies: These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some part of the site will not then work. These cookies do not store any personally identifiable information.
• Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying our browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
• Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
• Functional Cookies: These cookies enable the website to provide enhanced functionality and Personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.

We use additional technologies to help track user activities and preferences. Additionally, we may set cookies that monitor links to our website that we send to you (if you have consented to receiving emails from us). These cookies are used to track visitors to our Website sourced from these emails. To avoid these type of cookies, please follow the explanation below on how to change your browser cookie settings.

Third party companies like analytics companies and ad networks generally use cookies to collect user information on an anonymous basis. They may use that information to build a profile of your activities on the Website and other website that you have visited.

If you do not like the idea of cookies or certain types of cookies, you can change your browser’s setting to delete cookies that have already been set and to not accept new cookies.

CHANGES TO THIS PRIVACY AND COOKIE POLICY

From time to time, NeuroCare.AI may change the terms of this policy. Changes will take effect once they are posted online. If you do not agree with any of the amended terms, you must avoid any further use of the Website.

Other Terms and Conditions:

Your access to and use of the Services is subject to the Terms of Use.