Privacy Policy

Last Updated: 12 December 2023

Data Controller and Data Processor

Neuro Solutions Group’s business customers are the data controllers for most of the information that is entered into the Neuro Solutions Group applications, websites, and supporting systems or that is shared periodically with Neuro Solutions Group to deliver services. This positions Neuro Solutions Group as the data processor for most information stored and processed by Neuro Solutions Group. There are some pieces of information that are collected directly by Neuro Solutions Group to facilitate security, logging, and application performance. These items include the user’s IP address (if not available location may be tracked for legal purposes) and behavior within the Neuro Solutions Group applications. For these pieces of information, Neuro Solutions Group acts as the data controller and processor. Additionally, Neuro Solutions Group employs a variety of technologies and partners that periodically act as sub-processors (detailed list below). If users have any questions or concerns about the processing and handling of their personal information, they may reach out to Neuro Solutions Group directly by email at privacy@neurosolutionsgroup.com.

Types of Data Collected

The Neuro Solutions Group applications and supporting applications may collect personal data (e.g., page and link clicks, time on page) that the user may freely and with consent provide, or, in case of usage data, collect when using this website, or, in case of specific data needed to provide intended services.

On this website Neuro Solutions Group collects the following types of personal data: cookies (i.e., language), anonymous usage data, and freely provided email addresses (i.e., if provided to fill a Support/Contact Form).

Complete details on each type of personal data collected are provided in the dedicated sections of this Privacy Policy, or by specific explanation texts displayed before the data collection, or in Neuro Solutions Group specific application’s Privacy Policy.

Specific data is required for the Neuro Solutions Group applications and supporting applications to provide services. If data is mandatory in a specific application, it is noted throughout the application’s website. If the Neuro Solutions Group websites or other applications specifically state that data is not mandatory, users are free to not share this data without consequences to the availability or the functioning of the service (i.e., it is explicitly stated otherwise).

Users who are uncertain about which personal data is mandatory are welcome to contact Neuro Solutions Group at privacy@neurosolutionsgroup.com.

Any use of cookies (or other tracking tools) by the the Neuro Solutions Group website, other websites or applications and supporting applications serves the purpose of providing the service for which Neuro Solutions Group has been engaged; with end user consent, in addition to any other purposes described in the present document.

Furthermore, Neuro Solutions Group doesn’t share or sell any data unless mandatory to provide its services.

Mode, Place, and Methods of Processing the Data

Neuro Solutions Group takes appropriate security measures to prevent unauthorized access, disclosure, modification, or data destruction.

Data is processed using computers or tech-enabled tools, following organizational policies and procedures strictly related to the purposes indicated. In some cases, data may be accessible to Neuro Solutions Group privileged employees involved with the Neuro Solutions Group website’s operation, the Neuro Solutions Group web application (platform), and supporting applications.

Data may also be accessible to external parties appointed, if necessary, as data processors or sub-processors by Neuro Solutions Group. External parties may include third-party technical service providers, hosting providers, and IT companies.

Neuro Solutions Group may process personal data relating to users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • Provision of data is necessary for the performance of an agreement with explicit consent from the end user.
  • Processing is necessary for compliance with a legal obligation.
  • Processing is necessary for the legitimate interests pursued by the controller or by a third party.

In any case, Neuro Solutions Group will gladly help clarify the specific legal basis that applies to the processing, mainly whether the provision of personal data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

Retention Time

Personal data is processed and stored for as long as required to fulfill the purpose for which it is collected.

Therefore:

  • Personal data collected for the performance of a contract between Neuro Solutions Group and a business customer is retained until such contract has been entirely performed or the business customer asks for the data to be deleted.
  • Personal data collected for Neuro Solutions Group’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding Neuro Solutions Group’s legitimate interests within the relevant sections of this document or by contacting Neuro Solutions Group.

Neuro Solutions Group may be allowed to retain personal information for a more extended period whenever the user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Neuro Solutions Group may be obliged to retain personal data for a more extended period whenever required to perform a legal obligation or upon order of an authority.

Once the retention period expires, the user’s personal data will be securely deleted.

In the case of consent for data participation in research, Neuro Solutions Group’s enforced anonymization policy implies irreversible and untraceable data. Thus, while consent is ongoing, data is anonymized and funnelled into research database. Once consent is withdrawn, data is not shared or funnelled anymore. In the latter case, data is not removable since anonymized and untraceable as per Neuro Solutions Group’s policy.

The Purposes of Processing

The data concerning the user is collected to allow Neuro Solutions Group to provide its services, as well as for the following purposes: analytics, application user database management, managing contacts and sending messages and notifications, handling payments for a specific application or licence, interaction with external social networks and platforms, remarketing and behavioral targeting, contacting the user, displaying content from external platforms, hosting and backend infrastructure, interaction anti-spam protection.

Users can find further detailed information about such purposes of processing and the specific personal data used for each purpose in the respective sections of this document or in the Privacy Notice of Neuro Solutions Group’s products.

Detailed Information on the Processing of Personal Data

Personal data is collected for the following purposes and using the following services and third parties:

Analytics

The services contained in this section enable Neuro Solutions Group to monitor and analyze web traffic and can be used to keep track of user behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this application, to prepare reports on its activities, and to share the reports with other Google services.

Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Personal data collected: cookies and usage data.

Place of processing: US – Privacy Policy.

Google Ads Conversion Tracking (Google Inc.)

Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this application.

Personal data collected: cookies and usage data.

Place of processing: US – Privacy Policy. Privacy Shield participant.

Google Tag Manager (Google Inc.)

Google Tag Manager is an analytics service provided by Google Inc.

Personal Data collected: cookies and usage data.

Place of processing: US – Privacy Policy.

Contacting the User

Mailing List or Newsletter (The Neuro Solutions Group Web Application)

By registering on the mailing list or for the newsletter, the user’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Neuro Solutions Group’s applications. The user’s email address may also be added to this list due to signing up via the Neuro Solutions Group website.

Personal data collected: city, country, email address, first name, last name and usage data (mostly time on page and preferences like language).

Phone Contact (The Neuro Solutions Group Web Application)

Users that provide their phone number might be contacted for commercial, promotional or support requests purposes related to the Neuro Solutions Group application.

Personal Data collected: phone number.

Contact Form (The Neuro Solutions Group Web Application)

By filling in the contact form with their data, users authorize the Neuro Solutions Group application to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.

Personal data collected: city, cookies, country, email address, first name, last name and usage data (mostly time on page and preferences like language).

Displaying Content from External Platforms

This type of service allows users to view content hosted on external platforms directly from the pages of the Neuro Solutions Group web application and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when users do not use it.

Google Fonts (Google Inc.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal data collected: usage data and various types of data as specified in the service’s privacy policy.

Place of processing: US – Privacy Policy. Privacy Shield participant.

YouTube Video Widget (Google Inc.)

YouTube is a video content visualization service provided by Google Inc. that allows the Neuro Solutions Group website and Neuro Solutions Group web application to incorporate content of this kind on its pages.

Personal data collected: cookies and usage data.

Place of processing: US – Privacy Policy.

Handling Payments

Payment processing services enable Neuro Solutions Group applications to process payments by credit card, bank transfer, or other means. Neuro Solutions Group applications share only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable sending timed messages to the user, such as emails containing invoices or notifications concerning the payment.

More details are available in each Neuro Solutions Group application’s Privacy Notice.

Hosting and Back-End Infrastructure

This type of service has the purpose of hosting data and files that enable the Neuro Solutions Group website and Neuro Solutions Group applications to run and be distributed. Additionally, these services provide the infrastructure to run specific features or parts of the application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the personal data is stored.

When required, for legal and compliance purposes, some services or whole applications may be specifically located in a country or jurisdiction mandatory to offer application services.

More details are available in each Neuro Solutions Group application’s Privacy Notice.

Google Cloud Platform (GCP) (Google)

Google Cloud Platform is a hosting and backend service provided by Google Inc.

Personal data collected: various types of data as specified in the privacy policy of the service.

Place of processing: See the Google privacy policy – Privacy Policy.

Amazon Web Services (AWS) (Amazon)

Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.

Personal data collected: various types of data as specified in the privacy policy of the service.

Place of processing: See the Amazon privacy policy – Privacy Policy.

Managing Contacts and Sending Messages

This type of service makes it possible to manage a database of email contacts, phone contacts, or any other contact information to communicate with the user.

These services may also collect data concerning the date and time when the message was viewed by the user and when the user interacted with it, such as by clicking on links included in the message.

Customer.io

Customer.io is a customer engagement and retention platform that provides the functionality to integrate app analytics and marketing.

Personal data collected: email address, provided name, language and usage data.

Place of processing: US, EU – Privacy Policy.

AdWords Remarketing (Google Inc.)

Google Ads, formerly known as Google AdWords, is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this application with Google’s advertising network and the DoubleClick cookie.

Personal data collected: cookies and usage data.

Place of processing: US – Privacy PolicyOpt Out.

Remarketing with Google Analytics (Google Inc.)

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its cookies with the Google Ads advertising network and the DoubleClick cookie.

Personal data collected: cookies and usage data.

Place of processing: US – Privacy PolicyOpt Out. Privacy Shield participant.

Spam Protection

This type of service analyzes the traffic of the Neuro Solutions Group website and Neuro Solutions Group applications, potentially containing users’ personal data, with the purpose of filtering it from parts of traffic, messages, and content that are recognized as spam.

User Database Management

This type of service allows Neuro Solutions Group to build user profiles by starting from an email address, a personal name, or other information that the user provides to this application and then tracking user activities through analytics features. This type of data is used to build private profiles that Neuro Solutions Group can use for improving its applications and services.

Some of these services may also enable sending timed messages to the user, such as emails based on specific actions performed on the Neuro Solutions Group website and Neuro Solutions Group applications.

Selling Goods and Services Online

The personal data collected is used to provide the user with services or goods, including payment and possible delivery. The personal data collected to complete the payment may include the credit card information or the bank account used for the transfer, or any other possible means of payment. The kind of data collected by this application depends on the payment system used.

Further Information about Personal Data

The Rights of Users

Users may exercise certain rights regarding their data processed by Neuro Solutions Group.

In particular, users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent after they have previously given their consent to the processing of their personal data.
  • Object to processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their data. Users have the right to learn if Neuro Solutions Group is processing their data, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data undergoing processing.
  • Verify and seek rectification. Users have the right to verify their data accuracy and ask for it to be updated or corrected.
  • Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, Neuro Solutions Group will not process their data for any purpose other than storing it.
  • Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from Neuro Solutions Group.
  • Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used, machine-readable format, and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user’s consent, on a contract that the user is part of, or on precontractual obligations.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details About the Right to Object to Processing

Where personal data is processed for the public interest, in the exercise of an official authority vested in Neuro Solutions Group or for the legitimate interests pursued by Neuro Solutions Group, users may object to such processing by providing a ground related to their particular situation to justify the objection.

However, users must know that should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Neuro Solutions Group is processing Personal Data for direct marketing purposes, users may refer to the relevant sections of this document.

Neuro Solutions Group is not selling any data but may use it to provide services and relevant direct marketing purposes.

How to Exercise These Rights

Any requests to exercise user rights can be directed to Neuro Solutions Group through the contact details provided in this document (privacy@neurosolutionsgroup.com). These requests can be exercised free of charge and will be addressed by Neuro Solutions Group as early as possible within 60 business days.

Cookie Policy

The Neuro Solutions Group website and Neuro Solutions Group web applications use cookies.

The scope of data used in the cookies is about preferences (language, localization) and some basic usage data (e.g., last login date and time).

Additional Information about Data Collection and Processing

Legal Action

Users’ personal data may be used for legal purposes by Neuro Solutions Group in court or the stages leading to possible legal action arising from improper use of this application or the related services. The users declare they are aware that Neuro Solutions Group may be required to reveal personal data upon request of public authorities.

Additional Information About Users’ Personal Data

In addition to the information contained in this privacy notice, this application may provide users with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

System Logs and Maintenance

For operation and maintenance purposes, applications and any third-party services may collect files that record interaction with Neuro Solutions Group applications (e.g., system logs) using other personal data (e.g., IP Address) for this purpose.

Only privileged Neuro Solutions Group members with the required level of permissions may access production logs or data. Those activities are also monitored and traceable.

Information Not Contained in This Notice

More details concerning the collection or processing of personal data may be requested from Neuro Solutions Group at any time. Users may use the contact information at the beginning of this document.

How “Do Not Track” Requests are Handled

This application does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor “Do Not Track” requests, users should read their privacy policies.

Changes to This Privacy Notice

Neuro Solutions Group reserves the right to make changes to this privacy notice at any time by giving notice to users on this page and possibly within its applications or–as far as technically and legally feasible–sending a notice to users via any contact information available to Neuro Solutions Group. Users are strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed based on the users’ consent, Neuro Solutions Group shall collect new consent from the user where required.

Definitions and Legal References

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information—including a personal identification number—allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this application (or obtained by services employed in this application)can include: the IP addresses or domain names of the computers utilized, the Uniform Resource Identifier (URI) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the users’ browser and operating system, the various time details per visit (e.g., the time spent on each page within the application), and the information on the path followed within the application with particular reference to the sequence of pages visited, and other parameters about the device operating system or the users’ IT environment.

User

The individual using this application who, unless otherwise specified, coincides with the data subject.

Data Subject

The natural person to whom the personal data refers.

Data Processor

The natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller, as described in this privacy notice.

Sub-Processor

This refers to any additional third party who processes personal data on behalf of the data processor in fulfilling contractual obligations and services.

Data Controller

The person, public authority, agency, or other body that determines the purposes and means of processing personal data, including the security measures concerning the operation and use of this application.

Application(s)

The information technology system that collects and processes the personal data of the user.

Service

The service provided by the Neuro Solutions Group platform or Neuro Solutions Group team.

European Union (EU)

Unless otherwise specified, all references made within this document to the European Union (EU) include all current member states to the European Union and the European Economic Area.

Cookies

Small piece of data stored on the user’s device.

This privacy notice has been prepared based on provisions of multiple legislations, including:

  • Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation)
  • Quebec Chapter P-39.1 - Private Organizations with Law 25
  • The Privacy Act (Canada)
  • Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada)
  • Consumer Privacy Protection Act (CPPA) (Canada)
  • Children's Online Privacy Protection Act (COPPA) (US)
  • California Consumer Privacy Act (CCPA) (US - California)
  • California Privacy Rights Act (CPRA) (US - California)
  • Virginia Consumer Data Protection Act (VCDPA) (US - Virginia)
  • Colorado Privacy Act (CPA) (US - Colorado)
  • French Data Protection Act (Loi n78-17)
  • German Federal Data Protection Act
  • Telecommunications-Telemedia-Data Protection Act (Germany)
  • Belgian Data Protection Act
  • Spanish Organic Law on Data Protection and Guarantee of Digital Rights
  • Protection of Privacy Law (PPL) (Israel)
  • Privacy Protection Regulations (Israel)
  • Federal Act on Data Protection (nFADP) (Switzerland)

This privacy notice relates to the Neuro Solutions Group websites, applications, and supporting services unless otherwise stated within this document or in the specific product’s website, application or service privacy notice.