PRIVACY POLICY
PRIVACY POLICY – REVISED AS OF OCTOBER 6,2021
The purpose of this Privacy Policy (“Policy”) is to inform you about what information may be collected from you when visiting Neurohacker Collective, LLC (“Company”, “we,” “”us,” or “our”) websites (“Sites”), how such information will be used, with whom such information may be shared, the safeguards the Company has in place to protect such information, and how you can control our use of it.
Neurohacker Collective respects the privacy of our customers. How we handle your Personal Information is important to us. For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
By accessing the Sites and our services, you agree to our collection and use of Personal Information as described in this Policy and to our Terms and Conditions.
COLLECTION OF PERSONAL INFORMATION
In the 12 months prior to the date of this Policy we may have collected your Personal Information when you visited and interacted with the Sites, joined our Beta Test Program and submitted results and feedback to us as part of that program, logged into your account with us, placed an order on the Sites, joined our channel partner program, registered for or participated in one of our events, contacted us or voluntarily submitted information to us by email, text or phone. We will continue to collect Personal Information from the same sources,
The categories of Personal Information we may have collected from these sources during the 12 months preceding the date of this Policy, and will continue to collect, are as follows:
Personal identifiers: Name, billing and mailing address, email address, telephone numbers, customer number, account number and password, and IP address or other unique identifier. In addition, for our channel partners, this includes organizations with which you are affiliated; your website, Facebook and YouTube URLs; and your Twitter and Instagram handles.
Commercial and financial information: Records of products purchased, ordered, returned, or considered; other purchasing or consuming histories or tendencies; and credit card or other payment information.
Internet or other electronic activity information: Your device and browser type; your browsing and search history on our Sites; information regarding your interaction with our Sites and our advertisements; your interaction with links to Neurohacker promoted by our marketing partners (including those who participate in our affiliate marketing program).
Audio and visual information: Recordings of customer service calls for quality assurance purposes, and photographs of yourself that you voluntarily provide in connection with reviews of our services.
Inferences drawn from the categories of Personal Information identified above.
USES OF PERSONAL INFORMATION
We use your Personal Information to contact you and respond to your inquiries and requests, to provide goods or services to you and process payments and returns, to manage and maintain our relationships with you including for customer service, to manage our events, contact you to tell you about products and services offered by us as well as other promotions which we believe may interest you, to provide you with content we believe may be of interest to you, to personalize your visit to the Sites and improve your experience on the Sites.
We also use Personal Information about your use of our Sites to monitor or improve our Sites; for internal business analysis, including to help us design and enhance our products and service offerings; to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.
DISCLOSURES OF PERSONAL INFORMATION
We may share your Personal Information with our vendors and other third parties connected with the operation of our business, including to process payments; verify customer information; fulfill orders and provide shipping services; manage customer information and provide customer service; administer chargebacks; facilitate email communications; host our Sites and assist with other IT-related functions; improve and troubleshoot users’ experiences with the Sites advertise and market our products and services; assist in the operation of our programs including our affiliate marketing program; help us promote and manage events; provide analytics information; and provide legal and accounting services.
We may also disclose your Personal Information to third parties (including regulators and courts) to comply with legal or regulatory obligations or in response to valid legal requests, including to the extent required by law, regulation, subpoena or court order or otherwise in connection with a judicial, administrative or governmental proceeding or as requested by any governmental agency or regulatory authority; to detect and protect against fraud or any technical or security vulnerabilities; to respond to an emergency or otherwise to protect the rights, property, safety, or security of our business, third parties, or the public; or as part of any merger, acquisition, or sale of company assets.
MORE INFORMATION ABOUT COOKIES
The Sites use cookies, pixels, tags, mobile advertising identifiers, and other technologies commonly used in digital advertising. A cookie is a tiny element of data that our Sites can send to your browser, which may then be stored on your hard drive so we can recognize you when you return; the other technologies operate in a similar fashion.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
CALIFORNIA RESIDENTS
Under California law, residents of California may have certain rights with respect to their Personal Information. For an explanation of those rights and additional disclosures regarding California residents, please see our California Privacy Notice.
NEVADA RESIDENTS
Under Nevada law, residents of Nevada can direct businesses operating in that state not to sell their Personal Information. We do not sell Personal Information within the meaning of sale under Nevada law.
EUROPEAN RESIDENTS
Please see our EU/UK Privacy Policy for more information.
THIRD-PARTY WEBSITES
Our Sites may contain links to other third-party websites, which may have Privacy Policies/Statements that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the Privacy Policy/Statement posted on any website that you may access through our Sites.
SECURITY
Our Company maintains reasonable security measures consisting of physical, administrative and technical procedures and safeguards designed to protect your Personal Information. However, while we maintain reasonable security measures and strive to protect your Personal Information, we cannot guarantee or warrant its complete security.
PERSONAL INFORMATION OF MINORS
We do not knowingly collect Personal Information from children under the age of 13, nor do we share such information with third parties. Children under the age of 18 may use the Sites only with the involvement of a parent or guardian.
MODIFICATIONS TO POLICY
We reserve the right to change this Policy, along with any related provisions, at any time. Any changes to this Policy will be effective immediately. Be sure to review the Policy periodically to ensure familiarity with its most current version. You can easily confirm whether any revisions have been posted since your last visit by checking the date on which the Policy was last revised, which is set forth at the top of this Policy. If you disagree with the changes in our policy, however, please do not use the Sites after the posting of such changes online. By using the Sites following the posting of changes to this Policy, you agree to all such changes.
DO NOT TRACK
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Sites do not respond to browsers’ do not track signals.
ACCESSIBILITY
We are committed to ensuring that our communications, including the Sites, are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at (855) 281-2328 or support@neurohacker.com.
QUESTIONS OR COMMENTS OR TO CONTACT US
If you have questions or comments about this Policy, or you wish to confirm or make changes to information about you, please contact the customer care department by e-mail at support@neurohacker.com or phone at 1 (855) 281-2328 or by mail at: 5946 Priestly Dr., STE 104, Carlsbad, CA 92008, United States.
Information we collect
Information you provide to us
We collect the personal information you provide to us when you purchase our products online. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, and telephone number
- Commercial and Financial Information, including purchases and credit card or debit card number
- Biometric Information, including sleep, health, or exercise data
- Characteristics of Protected Classifications, including sex or gender
We collect the personal information you provide to us when you Newsletter Subscribers. The categories of information we may collect include:
- Personal Identifiers, including name, email address, and telephone number
We collect the personal information you provide to us when you Website Visitors. The categories of information we may collect include:
- Personal Identifiers, including name and email address
To the extent we process deidentified personal information, we will make no attempt to reidentify such data.
Information collected automatically
We automatically collect internet or other electronic information about you when you visit our website, such as IP address, browsing history and interactions with our website. We also collect geolocation data. This data may be collected using browser cookies and other unique personal identifiers.
Opt-Out Preference Signals. Your browser settings may allow you to automatically transmit the Global Privacy Control (GPC) signal to online services you visit. When we detect such signal, we place a U.S. Privacy String setting in your browser so that any third party who respects that signal will not track your activity on our website. GPC is supported by certain internet browsers or as a browser extension. You can find out how to enable GPC here.
Information from other sources
We may collect personal information about you from third-party sources, including Ad Networks, Data Analytics Providers, and Social Networks.
How long we keep your data
We do not retain data for any longer than is necessary for the purposes described in this Policy.
We generally retain data according to the guidelines below.| Type of Data | Retention Period |
|---|---|
| Cookies and online data we collect while you use our website, including Internet Activity, Geolocation data | We delete or anonymize data concerning your use of our website within 2 years of collecting it. |
| Data we collect in order to process and ship orders you place with us, including Name, Email address, Postal address, Telephone number, Credit card or debit card number | We keep personal information related to products and services you purchase for as long as the personal data is required for us to fulfill our contract with you, and for 5 years from your last purchase with us. We may keep data beyond this period in anonymized form. |
| Data we collect when you contact us for customer support and other inquiries, including Name, Email address, Telephone number, Purchases | We keep customer feedback and correspondence with our customer service for up to 2 years to help us respond to any questions or complaints. We may keep data beyond this period in anonymized form. |
| Data we collect when you sign up for promotional and marketing communications, including Name, Email address, Telephone number | Where you have signed up to receive promotional and marketing communications from us, we will retain any data collected until you opt out or request its deletion. We may keep data beyond this period in anonymized form. We will further retain a record of any opt-outs in order to prevent sending you future communications. |
| Data we collect when you review our products, answer surveys, or send feedback, including Sleep, health, or exercise data, Name, Email address, Postal address, Purchases, Sex or gender | We retain review, survey, and feedback data for up to 5 years following your last contact with us. We may keep data beyond this period in anonymized form to help improve our products and services. |
| Data we collect in connection with privacy requests, including Online Identifiers, Name, Email address | We retain records related to privacy requests for a minimum of 24 months following the completion of the request. |
| Data we collect for security purposes, including Email address | We retain security-related data as long as necessary to comply with our legal obligations and to maintain and improve our information security measures. |
How we share and disclose information
Information Disclosed for Business or Commercial Purposes in the Last 12 Months, and Categories of Parties Disclosed To
We may disclose the following personal information about you when you purchase our products online:
| Personal Information Disclosed | Recipient (by Category) |
|---|---|
| Personal Identifiers | Service Providers and Payment Processors |
| Online Identifiers | Sales & Marketing Tools, Service Providers, Payment Processors, Ad Networks, and Data Analytics Providers |
| Internet Activity | Sales & Marketing Tools, Service Providers, Ad Networks, and Data Analytics Providers |
| Commercial and Financial Information | Service Providers, Sales & Marketing Tools, Payment Processors, Ad Networks, and Data Analytics Providers |
| Biometric Information | Service Providers |
| Geolocation Information | Service Providers |
| Characteristics of Protected Classifications | Service Providers |
We may disclose the following personal information about you when you Newsletter Subscribers:
| Personal Information Disclosed | Recipient (by Category) |
|---|---|
| Personal Identifiers | Service Providers |
| Online Identifiers | Service Providers, Ad Networks, Data Analytics Providers, and Sales & Marketing Tools |
| Internet Activity | Service Providers, Ad Networks, and Data Analytics Providers |
| Geolocation Information | Service Providers |
We may disclose the following personal information about you when you Website Visitors:
| Personal Information Disclosed | Recipient (by Category) |
|---|---|
| Personal Identifiers | Service Providers |
| Online Identifiers | Service Providers, Ad Networks, Data Analytics Providers, and Sales & Marketing Tools |
| Internet Activity | Service Providers, Ad Networks, and Data Analytics Providers |
| Geolocation Information | Service Providers |
California Privacy Notice (CCPA)
This section provides additional information for California residents under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered "personal information," such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.
Collection and Disclosure of Personal Information
The personal information we collect is described above in Information we collect. The personal information we disclose for business or commercial purposes is described above in How we share and disclose information. The length of time for which we retain personal information is described above in How long we keep your data.
Business and Commercial Purposes for Collection
We collect personal information for the following business purposes:
- Conducting Surveys
- Creating Customer Profiles
- Fulfilling Customer Orders
- Processing Payments
- Providing Customer Support
- Sending Promotional Communications
We also "share" and "sell" (as defined in the CCPA) personal information for commercial purposes, including to advertise and market our products.
Information “Sharing” and “Selling”
We “share” certain personal information with third party ad networks for purposes of behavioral advertising, including: Commercial and Financial Information, Internet Activity, and Online Identifiers. This allows us to show you ads that are more relevant to you.
We use third party data analytics providers and this may be considered a “sale” of information under the CCPA.
You may opt-out of these data practices here.
CCPA Rights
Your CCPA rights are described below. You can make a Request to Know or a Request to Delete under the CCPA by submitting a Privacy Request at the top of this page, or by clicking here.
Right to Know
You have the right to request to know the following about the personal information we have collected about you in the past 12 months:
- the categories and specific pieces of personal information we have collected about you
- the categories of sources from which we collect personal information about you
- the business and commercial purposes for which we collect personal information
- the categories of third parties with whom we share the information
- the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose
The information we would provide to you in response to a Request to Know Categories is contained in this Privacy Notice. To access the specific personal information we have about you, submit a Request to Know via the link above. If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal information about you that you have provided to us. We will permanently delete from our records any personal information that is not necessary for our business operations and direct our service providers to do the same.
We consider information to be necessary for our business operations if it is used to:
- Complete an obligation to you that you have requested
- Detect and resolve issues related to security or functionality
- Comply with legal obligations
- Enable solely internal uses
Right to Non-Discrimination
If you exercise your CCPA consumer rights:
- We will not deny goods or services to you
- We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
- We will not provide a different level or quality of goods or services to you
Right to Opt-Out
You have the right to opt-out of any selling and sharing of your personal information.
You may exercise your right to opt-out here.
Request Verification
Before we can respond to a Request to Know or Request to Delete, we will need to verify that you are the consumer who is the subject of the CCPA request. Verification is important for preventing fraudulent requests and identity theft. Requests to Opt-Out do not require verification.
Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request.
For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required by the CCPA.
In some cases, we may have no reasonable method by which we can verify a consumer's identity. For example:
- If a consumer submits a request but we have not collected any personal information about that consumer, we cannot verify the request.
- If the only data we have collected about a consumer is gathered through website cookies (i.e. the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.
Authorized Agent
A California resident's authorized agent may submit a Request to Know or a Request to Delete under the CCPA by emailing us at privacy@neurohacker.com. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.
If you have trouble accessing this notice, please contact us at privacy@neurohacker.com.
Contact Us
If you have any privacy-related questions, please send them to privacy@neurohacker.com.
Virginia Privacy Notice (VCDPA)
This section provides additional information for Virginia residents under the Virginia Consumer Data Protection Act (VCDPA). The terms used in this section have the same meaning as in the VCDPA. This section does not apply to information that is not considered "personal data," such as deidentified or publicly available information as defined in the VCDPA.
Collection and Disclosure of Personal Information
The personal data we collect is described above in Information we collect. The personal data we disclose to third parties and the categories of third parties to whom we disclose personal data is described above in How we share and disclose information. The length of time for which we retain personal information is described above in How long we keep your data.
Purposes for Processing
We process personal information for the following purposes:
- Conducting Surveys
- Creating Customer Profiles
- Fulfilling Customer Orders
- Processing Payments
- Providing Customer Support
- Sending Promotional Communications
Data “Selling” and Targeted Advertising
We process personal data for purposes of targeted advertising (as defined in the VCDPA), including online identifiers and internet activity. This allows us to show you ads that are more relevant to you.
You may opt-out of these data practices here.
Profiling
The VCDPA gives consumers the right to opt out of automated profiling that produces legal or similarly significant effects, such as approval for a loan, employment, or insurance.
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
VCDPA Rights
Your VCDPA rights are described below. You can make a Privacy Request by clicking the link at the top of this page, or by clicking here.
Right to Access
You have the right to confirm whether we are processing personal data about you and to access such data. Where processing is carried out by automated means, you have a right to receive a copy of your personal data in a portable and readily usable format that allows you to transmit your data to another controller.
If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal data provided by or obtained about you. We will permanently delete any such personal data from our records and direct our processors to do the same. However, we may retain your personal data if it is necessary for certain purposes, including the following:
- To comply with legal obligations
- To comply with an official investigation or cooperate with law-enforcement agencies
- To establish or defend legal claims
- To complete an obligation to you that you have requested
- To respond to security incidents, fraud, harassment, and other similar activity
- To identify and repair technical errors
- To conduct internal research to develop, improve, and repair our products and services
- For internal operations that are reasonably aligned with your expectations
Any personal data retained for these purposes will not be processed for other purposes.
Right to Non-Discrimination
If you exercise your VCDPA consumer rights:
- We will not deny goods or services to you
- We will not charge you different prices or rates for goods or services
- We will not provide a different level or quality of goods or services to you
However, we may offer a different price, rate, level, quality, or selection of products or services if your personal data is required in order to provide those products or services and you have exercised your right to opt out, or the offer is related to a voluntary loyalty or rewards program.
Right to Opt-Out
You have the right to opt-out of any selling of your personal data, processing of your personal data for purposes of targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects for you.
You may exercise your right to opt-out here.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Right to Appeal
If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time.
If you believe your rights have been violated and you are not able to resolve the issue directly with us, you may file a complaint with the Virginia Attorney General’s Office.