PRIVACY POLICY

Introduction

Neuro-Link Interactive CC 1999/004504/23; Neuro-Link USA LLC 1377925; Neuro-Link Europe LTD 09314096, is referred to in this Privacy Policy as ‘’Neuro-Link,’’ ‘’we,’’ ‘’us’’ and ‘’our.’’

This Privacy Policy applies to i) all users of Internet websites published by Neuro-Link, ii) all users of Neuro-Link products and services, and iii) other individuals whose personal data (as described below) is collected or processed by Neuro-Link. All such individuals are referred to in this Privacy Policy as ‘’you’’ and ‘’your.’’

In this Privacy Policy we describe the types of personal data we may collect from you and how we collect, use, share, disclose and store it. We also explain your choices regarding our use and processing of your personal data.

As used in this policy, “POPIA” means the Protection of Personal Information Act 4 of 2013, South Africa, “GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation) and “CPPA” means the California Consumer Privacy Act.

Neuro-Link is committed to protecting your privacy and ensuring you have a positive experience on our website and in using our products and services. Neuro-Link knows that you care how information about you is used and shared and appreciates your trust that we will do so as carefully and sensibly as possible. Neuro-Link is committed to the security, availability, confidentiality, and processing integrity of all information collected. This privacy policy is applicable to all its online platforms, including its commercial website and application products, administrative tools, assessment portals, surveys, and e-commerce sites. By using the Site, you are consenting to this privacy policy and the collection, use and disclosure of your personal information by Neuro-Link as outlined in this privacy policy. If this privacy policy is not acceptable to you, please do not submit any of your personal information.

 

Information Collected by Neuro-Link

The information Neuro-Link collects is used to deliver our services, personalize, and continually improve the online experience of Neuro-Link customers. All information is gathered and stored in secure databases in the United States. Here are the types of information Neuro-Link gathers:

Personal Information You Provide

Neuro-Link receives and stores any personal information you enter on Neuro-Link’s online platforms (neurolink.company; neuro-link.net). We may choose to collect personal information from you via the Site through the use of enquiry, registration forms, search for a product, take an assessment or course, place an order, provide information in your account or communicate with us by e-mail or otherwise. As a result of those actions, you might supply Neuro-Link with information such as your name, last name, address, email address, age, gender, phone number, credit card information, people (including addresses, phone numbers and people you list when enquiring) to whom purchases have been shipped, people (including addresses and phone numbers) listed in your Neuro-Link shipping address book, content of reviews and e-mails to us, or replies you submit during the assessments. You may choose not to provide certain information. However, your decision not to provide information may limit your ability to take advantage of all available online features. Neuro-Link uses the information that you provide for purposes such as generating personal characteristic information, more efficiently and accurately responding to your requests, and customizing and/or improving our products.

Automatic Information

Neuro-Link receives and stores certain types of information whenever you interact with its online platforms (neurolink.company; neuro-link.net) for internal statistical purposes. For example, like many websites, Neuro-Link uses “cookies” to store your login information. Other examples of information collected and analysed include the Internet protocol (IP) address used to connect your computer to the Internet, login info, e-mail address, password, computer, and connection information such as browser type and version, operating system and platform, purchase history, the full Uniform Resource Locators (URL) clickstream to, through, and from our website, including date and time, cookie number, and products you viewed or searched for.

Our legal basis under the GDPR for processing log file data includes is our legitimate interest in providing the technically error-free and optimized delivery of our services in accordance with (GDPR Article 6, Section 1(f)).

Information necessary to communicate with you

To facilitate communications with you, we may collect and process your contact information including (but not limited to) your name, your employer’s name, your address (including your country location), department, job title and email address. We may also collect and process your personal email address, personal mailing address, and mobile phone number.

We may process your contact information to transact business with you and your company and to deliver products and services to you. We may also use this information to help us understand our customers’ needs and interests to better tailor our products and services to meet your needs. E-mail Communications: If you do not want to receive e-mail or other mail from us, please unsubscribe by contacting the information officer at info@neurolink.company.

Our legal bases under the GDPR for processing this data include:

  • the processing is necessary for the performance of a contract to provide you with our goods or services (GDPR Article 6, Section 1(b)); or
  • the processing is necessary for legitimate interests we pursue in operating our business and providing products and services to you (GDPR Article 6, Section 1(f)).

Information necessary to access products and services

Account information

If you choose to create an account to access our online products and services, we will collect and process, in addition to the contact information described above, a login name and password chosen by you.  Your account will store and provide you with information regarding assessments you have taken, your assessment results, activities in which you have participated, and similar information associated with services you obtain from us.

Our legal bases under the GDPR for processing this data include:

  • the processing is necessary for the performance of a contract to provide you with our goods or services (GDPR Article 6, Section 1(b)); or
  • the processing is necessary for legitimate interests we pursue in operating our business and providing products and services to you (GDPR Article 6, Section 1(f)).

Responses to assessment questions

If you choose to participate in an assessment, we will first obtain your consent to process your personal data, including contact information, assessment responses, and resulting profiles and reports as reasonably necessary to conduct the assessment and provide results to you. Optional demographic and research information may also be requested. We use assessment data to create and deliver reports, such as the Neuro Agility Profile™ (NAP™) and 12 Emotional Intelligence Competencies Profile 360™ reports, team reports and other reports. Your consent will establish a legal basis for such processing in accordance with GDPR Article 6, Section 1(a). Prior to your taking an assessment, the consent document will provide you with specific information regarding how your data will be processed.

Processing payments

To enable purchases of products and services, we collect data necessary to process payments. All payment transactions are processed through a gateway provider and credit card information is not stored or processed on our servers, if that is your chosen method of payment.

Our legal bases under the GDPR for processing this data include:

  • the processing is necessary for the performance of a contract to provide you with our goods or services (GDPR Article 6, Section 1(b)); or
  • the processing is necessary for legitimate interests we pursue in operating our business and providing products and services to you (GDPR Article 6, Section 1(f)).

Information we use to provide you with information about our products and services

To provide you with information regarding our products and services, we may collect your first and last names, telephone number, address, and email address.  Your consent will establish a legal basis for such processing in accordance with (GDPR Article 6, Section 1(a)). Your consent will normally be established by your clicking a box indicating such consent.  You may withdraw your consent at any time by sending a request to info@neurolink.company.

Neuro-Link does not link IP addresses to personally identifiable information on its website; however, we reserve the right to link IP addresses and other information supplied by the Internet Service Provider (ISP) to personally identifiable information in order to protect the integrity of our system and for security purposes.

The Internet is a global environment. By using this site and sending information to us electronically, you consent to trans-border and international transmission of any data that you may choose to supply us. Information transmissions to this site and emails sent to us may not be secure. Given the inherent operation and nature of the Internet, all Internet transmissions are done at the user’s own risk.

Neuro-Link also collects and stores individual data to maintain and issue a unique session ID for you while you are using this website.

Neuro-Link does not warrant, and is not responsible for, the accuracy of information about you that may be supplied to us through your email or through any other submission of personal information through this website.

Other Information and Purposes

We also use personal data, to the extent necessary to:

  • protect against and prevent fraud, legal claims, and liabilities; and to manage associated risk exposure;
  • respond to your inquiries and requests;
  • process and manage opt-out or unsubscribe requests;
  • comply with applicable laws, regulations, codes, and industry standards and practices;
  • respond to subpoenas or to orders of a court or government agency; and
  • establish, exercise, or defend legal claims, including, without limitation, to protect our rights and/or property.

Our legal bases under the GDPR for processing this data include:

  • the processing is necessary for the performance of a contract to provide you with our goods or services (GDPR Article 6, Section 1(b)); or
  • the processing is necessary for legitimate interests we pursue in operating our business and providing products and services to you (GDPR Article 6, Section 1(f)).

 

Cookies

Cookies are small text files that a website transfers to your computer’s browser. Cookies are used by Neuro-Link to measure traffic patterns, personalize content, and control security. The cookies we use supply non-personally identifiable information, but they may identify your computer, browser and Internet specifications.

Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service.

Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

Security Cookies. We use Security Cookies for security purposes.

 

Use of Information

We may process personal information collected via the Neuro-Link site for the purposes of:

  1. To provide you with account information
  2. To inform you of the latest news or new developments on or any changes to the services provided via the Neuro-Link site
  3. To provide and maintain our service
  4. To notify you about changes to our service
  5. To allow you to participate in interactive features of our service when you choose to do so
  6. To provide customer support
  7. To gather analysis or valuable information so that we can improve our service
  8. To monitor the usage of our service
  9. To detect, prevent and address technical issues

 

How Neuro-Link Shares Personal Data

Your personal data will be accessible by our employees who require access in order to fulfill your requests and orders and to further our business interests as described above. We may share your personal data with our partners, and with our practitioner licensees, distributors, resellers and contracted service providers to enable these organizations and individuals to provide our products and services to you, for customer support, marketing, technical operations and account management purposes, and to perform other activities described in this Privacy Policy.

Neuro-Link does not sell, rent, gift, loan, trade or lease any personal data and we do not disclose personal data to third parties for any purposes unrelated to our own business as described in this Privacy Policy.

Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Contractors and service providers that process personal data on our behalf must sign contracts with us that conform to the requirements of GDPR Article 28, Section 3 and other applicable laws.

Examples of data processing services that may be performed by contractors on our behalf include:

  • hosting our websites and services;
  • hosting our email server;
  • processing your orders and payments;
  • maintaining, enhancing, or adding to the functionality of our websites;
  • collecting web analytics data; and
  • performing other administrative services.

Other parties with whom we may share personal data include:

governmental authorities pursuant to applicable laws or court process, or as we reasonably deem necessary to prevent harm, financial loss, fraud or illegal activity;

the successor in interest to all or a portion of our business or assets; provided that should such a transfer occur, we will require such successor to agree in writing to use, protect, and maintain the security, integrity, and confidentiality of the transferred personal data in accordance with our Privacy Policy; and

others pursuant to consent obtained from you.

If you participate in taking the NAP™ preference assessment or other assessments offered by us, we may share your contact information, assessment responses, and assessment results with certified practitioners who have been accredited by Neuro-Link to administer assessments and interpret assessment results and reports. We may also share such data with persons directly assisting certified practitioners. Before receiving your data, all persons described in this paragraph must have: (i) agreed to protect the data and to use it only for the purposes described in this paragraph, and (ii) been determined by us to have a legitimate need to access assessment data in order to facilitate, administer or coordinate assessments.

 

Transfer of Information

Your Personal Data may be collected, transferred to and stored by us in the United States which is not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the EEA. We ensure that the recipient of your Personal Data offers an adequate level of protection and security, for example by entering into standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (GDPR Article 46) or other applicable regulators.

In other cases, we will seek your prior consent before transferring your personal data to countries not determined to ensure an adequate level of data protection within the meaning of the applicable data protection laws and regulations.

Neuro-Link is committed to maintaining a healthy relationship with our clients and values the information provided on its online platforms. This includes contact forms, feedback, and email or download requests. All information you, our valued customer, provide us will be treated with the greatest respect and will be kept private.

We may disclose personal information to third parties where:

  1. we have received signed consent;
  2. we use third parties to assist us in providing services and you have elected to receive one of those services. The third-party would only be allowed to use your information for the purposes of providing that service to you; or
  3. Legal Requirements: Neuro-Link may disclose any information about you to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect the property and rights of Neuro-Link or a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

 

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 

Security of Information

Neuro-Link is very concerned about safeguarding the confidentiality of your information. We use a variety of industry-standard administrative, physical, and security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.

All payment transactions are processed through a gateway provider and credit card information is not stored or processed on our servers.

It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer. By using the Site, you are consenting to this privacy policy and the collection, use and disclosure of your personal information by Neuro-Link as outlined in this privacy policy. If this privacy policy is not acceptable to you, please do not submit any of your personal information.

 

Retaining and Storage of Personal Information

We will retain your personal data for a period of time consistent with the original purpose of its collection. We also may retain your personal data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.  If your employer or other organization has paid for your assessment(s) and account access, we may agree to delete your personal data from our systems when so instructed by the organization.  We may also delete your personal data for purposes that we determine necessary at our reasonable discretion.

Personal data is stored on servers and systems that are owned by us or by contractors engaged by us under written agreements that comply with GDPR Article 28, Section 3 and this Privacy Policy. We maintain appropriate technical, administrative and physical safeguards to protect personal data received or collected by us. We review, monitor and evaluate our privacy practices and protection systems on a regular basis. Transmission of personal data is protected by SSL encryption when it is exchanged between your web browser and Neuro-Link. We also provide secure https access to the neurolink.company; neuro-link.net and neuro agility websites. All infrastructure is protected by a virtual private cloud, and access to that infrastructure by administrators is controlled via zero trust security web portal which requires two-factor authentication. Notwithstanding the foregoing measures, transmissions over the Internet or a mobile network are not 100% secure and we do not guarantee the security of transmissions. We are not responsible for any errors by individuals in submitting personal data to Neuro-Link.

 

Children

We do not knowingly market our products or services to, children under the age of 18. We may ask users for their age to ensure that we are not collecting information from children under age 18 or to identify when additional steps may be necessary in connection with information collected from persons as required by the jurisdiction in which they reside. If we learn that we have collected personal data from a child under age 18 without parental consent, we will delete that information as quickly as possible.

If a parent chooses to have their child participate in an assessment, we will first obtain parental consent to process their personal data (name, last name, date of birth, gender), assessment responses, and resulting profiles and reports as reasonably necessary to conduct the assessment and provide results to you. Optional demographic and research information may also be requested. We use assessment data to create and deliver reports, such as the Neuro Agility Profile™ (NAP™) and 12 Emotional Intelligence Competencies Profile 360™ reports, team reports and other reports. Parental consent will establish a legal basis for such processing in accordance with GDPR Article 6, Section 1(a). Prior to your taking an assessment, the consent document will provide you with specific information regarding how your data will be processed.

 

Access to Information and Your Rights

Persons whose personal data is governed by the POPIA, GDPR, the CCPA and other laws have several rights related to the processing of their data which are explained below. We extend these rights to everyone whose personal data we process.

The following rights are also available to you:

The right to request access to personal data (GDPR Article 15; CPPA 1798.110(a)) — You have the right to obtain confirmation from us regarding whether we process personal data about you, and, where that is the case, access to the personal data and certain information about how and why we process your personal data, including:

  • the categories of personal information we have collected about you;
  • the categories of sources from which the personal information is collected;
  • the business or commercial purpose for collecting or selling personal information;
  • the categories of third parties with whom we share personal information; and
  • the specific pieces of personal information we have collected about that you.

The right to rectification of personal data (GDPR Article 16) — You have the right to rectification and/or completion if the personal data concerning you is incorrect or incomplete.

The right to be forgotten/right to erasure (GDPR Article 17; CPPA 1798.105) — You have the right to obtain the erasure of your personal data where one of the following grounds applies:

  • your personal data are no longer necessary in relation to the purpose for which they were collected or otherwise processed;
  • you withdraw your previously given consent and we have no other legal ground for the processing;
  • your personal data have been unlawfully processed;
  • your personal data must be erased for compliance with a legal obligation; or
  • based only on your request for any reason or no reason, unless an exception under CCPA 1798.105(d) applies.

The right to restrict processing of your personal data (GDPR Article 18) — You have the right to restrict processing of your data under the following conditions:

  • the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
  • your personal data have been unlawfully processed and you request the restriction of processing instead of deletion;
  • we no longer need the personal data for the purpose of the processing, but the personal data is required by you for the establishment, exercise or defense of legal claims; or
  • you have objected to processing pursuant to GDPR Article 21, Section 1 and it has not been determined whether the legitimate grounds of us override those of you.

The right to object to processing of your personal data (GDPR Article 21) — You have the right to object to our processing of your personal data based on legitimate interests (GDPR Article 6, Section 1(f)), for the performance of a task carried out in the public interest (GDPR Article 6, Section 1(e)) or for direct marketing purposes.

The right to data portability (GDPR Article 20) — You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller without hindrance from us, as far as:

  • the processing is based on consent or on a contract pursuant to GDPR Article 6, Section 1(b); or
  • The processing is carried out by automated means.

The right to lodge a complaint with a supervisory authority –– You have the right to lodge a complaint with the supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement.

Your exercise of the foregoing rights is subject to our verification that you are the person to whom the information pertains and other requirements of the applicable laws.

You are not required to provide us with any personal data we may request. However, if the requested information is necessary for us to provide any product, service or information requested by you, we will be unable to fulfill your request.

Neuro-Link will provide the personal information described above free of charge, but if requests from you are unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request. Neuro-Link may also grant you access to the following information about you for the limited purpose of viewing and, in certain cases, updating that information. This list may change as the Neuro-Link online platforms evolve.

  1. Your Account
  2. Your Shopping Cart
  3. Your Recent Purchases
  4. Your Assessments and Course Materials

In cases where you have given us your consent to collect and use your personal data, you have the right to withdraw that consent at any time (without affecting the lawfulness of processing based on your consent before its withdrawal). An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query via email to info@neurolink.company.

As discussed above, you can always choose not to provide information. Please be advised, however, that certain information may be required in order to complete a product or fully utilize our services.

 

Changes to Privacy Policy

Neuro-Link reserves the right to change the terms of this Privacy Policy from time to time by posting an updated Privacy Policy. We encourage you to review this Privacy Policy periodically for any changes or updates.

 

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at info@neurolink.company. You may also contact us through our Customer Service Center:

South Africa: +27 12 020 0046

Neuro-Link Interactive CC.

21 Sauer Place

Faerie Glen

Pretoria

South Africa

0081

Privacy Policy Effective Date: 2022-04-01

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