Original creation date: December 2nd, 2021
Pursuant to Art. 4, para 7 of Regulation (EU) 2016/679 (GDPR), ‘Data controller’ means the natural or legal person that determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
For the purposes of this document, the Neuroart App or Website consists of products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us or mobile apps, online platform, official social media platforms, or other online properties through which we provide the Service.
For the purposes of providing online access to Neuroart App or Website under the General Terms and Conditions of use, the responsible Data Controller is SIA Neuroart Lab.
Neuroart App or Website is designed for personal and business purposes and may be used by individuals or entities. In case you are registering for and/or using the service on behalf of an entity we will treat you as an authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself, you have received prior consent from that other person to provide their personal information to us.
What Information We Collect
You are informed that there are three general categories of information that is collected from you which is differentiated on grounds as defined by the General Data Protection Regulation and other applicable data protection national laws.
Information that we collect in order to perform our legal obligations and in order to provide the Neuroart App or Website as part of our Agreement with you.
We ask for and collect from you the following personal information when you use the Neuroart App or Website. This information is necessary for us to comply with our regulatory obligations and for the adequate performance of the contract between you and us. Without it, we may not be able to provide you effectively the Service for which you register.
Registration and Use of Account Information
When you sign up for the Neuroart App or Website, we require certain personal information such as:
- First name and surname
- Date of birth
- Email address
- Registered address
- Mobile telephone number
- Identification document and all data from the identification document
- Type of identification document
- Issue date
- ID number
- Issuing authority
- And other data which we may choose to collect in our enrollment forms, which is necessary for your identification and verification.
Identity Verification Information In accordance with our legal obligations under the relevant Anti-money laundering and anti-terrorism financing regulations, we are obliged to verify your identity or the identity of the authorized user who is opening the Account (in case of a company or other entity, referred to as “user opening the Account”).
Risk and Fraud related information
In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations, we collect personal data regarding you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Neuroart App or Website through partnerships, or about your experiences and interactions from our partners and networks.
Source of income, annual estimate over the account, business activity details In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations, we collect personal data regarding you related to your sources of income and any other similar financial information about you which would help us prevent money laundering and/or terrorism financing.
Log data and device information
We automatically collect log data and device information when you access and use the Neuroart App or Website, even if you have not created an Account or logged in. That information includes, among other things: details about how you’ve used the Neuroart App or Website, IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Neuroart App or Website. We collect this information in relation to our legal obligation to provide you with secure methods of controlling your assets and your personal data.
Information that We collect with Your consent
You may choose to provide us with additional personal information in order to obtain a better user experience when using the Neuroart App or Website. This additional information will be processed based on your consent. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your online account, respond to surveys, participate in promotions, or use other features of the Neuroart App or Website.
Information We Collect from Your Use of the Neuroart
App or Website When you use the Neuroart App or Website, we may collect information, including personal information, about the services you use and how you use them. This information is necessary given our legitimate interest in being able to provide and improve the functionalities of the Neuroart App or Website.
When you use certain features of Neuroart App or Website, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions. The legitimate interests that we pursue with this processing is the identification of location-specific problems (i.e. coverage problems for SMS-sending purposes) and other statistical information, which helps us improve our services.
We collect information about your interactions with the Neuroart App or Website such as your usage of any Apps or Functionalities, and other interactions with the Neuroart App or Website. The legitimate interests that we pursue with this processing is a collection of crash reports and other statistical information, which helps us improve our services.
Cookies and Similar Technologies SIA
Neuroart Lab does not track its customers over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on our websites may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific Neuroart website from a certain IP address. See your web browser’s documentation for information on how to enable DNT signals and learn about other mechanisms that enable consumers to exercise choice about behavioral tracking. The information we collect automatically is statistical data and may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: Estimate our audience size and usage patterns.
Web Beacons Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not control these third-parties’ tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
To present our Website and its contents to you. To enable your use of the Neuroart platform and to process transactions and send notices about your transactions. To provide you with information, products, or services that you request from us. To fulfill any other purpose for which you provide it. To provide you with notices about your account. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. Resolve disputes, collect fees, and troubleshoot problems. To notify you about changes to our Website or any products or services we offer or provide though it. To allow you to participate in interactive features on our Website. In any other way we may describe when you provide the information. For any other purpose with your consent. We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form) or adjust your user preferences in your account profile.
The technologies we use for this automatic data collection may include:
Disclosure of Your Information
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Promotional Offers from the Company
If you do not wish to have your e-mail address or contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to information provided to the Company as a result of a service purchase, service experience, or other transactions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
Accessing and Correcting Your Information
Please be advised that when you use the Neuroart App or Website, we automatically collect some of the personal information described in the sections above such as Geo-location Information, Log Data and Device Information, Cookies and Similar Technologies, Payment Transfer and NRT Token Transfer Information.
How We Use The Information We Collect
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Neuroart App or Website, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.
Providing the Neuroart App or Website Authenticate your access to your online account or your payment instrument (Virtual Wallet); Detect and prevent fraud, abuse, security incidents, and other harmful activity by blocking the Neuroart service or by applying other fraud prevention measures; Conduct security investigations and risk assessments; Conduct checks against databases and other information sources; Comply with legal obligations (such as anti-money laundering regulations); Enforce our rights, interests and claims arising from the Legal Agreements. We process this information given our legitimate interest in improving the Neuroart App or Website and our Users’ experience with it, and where it is necessary for the adequate performance of the Agreement with you as well as to comply with applicable laws.
Provide, Improve, and Develop the Neuroart App or Website. Enable you to access and use the Neuroart App or Website; Process purchase payments, issue invoices and or other kind of payment documents for the processed order; Operate, protect, improve, and optimize the Neuroart App or Website and your experience, such as by performing analytics and conducting research; Provide customer service. Send you service or support messages, updates, security alerts, and account notifications; To operate, protect, improve, and optimize the Neuroart App or Website and experience, to personalize and customize your experience, introduce you to our other Services, we conduct profiling based on your interactions with the Neuroart App or Website. We process this information given our legitimate interest in improving the Neuroart App or Website, and where it is necessary for the adequate performance of the contract with you.
Create and Maintain a Secure Environment Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity; Conduct security investigations and risk assessments; Verify or authenticate information or identifications provided by you; Conduct checks against databases and other information third party sources, including background, data providers to the extent permitted by applicable laws and with your consent where required; Resolve any disputes between you and any of our clients and other users and enforce our agreements with third parties; Enforce our legal rights. We process this information given our legitimate interest in protecting the Neuroart App or Website, to measure the adequate performance of our Agreement with you, and to comply with applicable laws.
With Whom Do We Share Personal Data With other members of the corporate family of: We may share your Personal Data with members of SIA Neuroart Lab group of companies or within our extended family of companies that are related by common ownership or control, so that we may provide the Services you have requested or authorized or to manage the risk, or to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of the Neuroart App or Website and communications.
With third part service providers: We may share personal information with third party service providers that support us in providing the Neuroart service, products and/or services with functions at our decision and our behalf. These third-party service providers may for example:
We may share information about you with other parties for our legitimate interest or as permitted or required by law, including:
If we need to do so to comply with a law, legal process or regulations; To law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to us; If we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; To protect the vital interests of a person; To investigate violations of or enforce a user agreement or other legal terms applicable to any service; To protect our property, services and legal rights; To facilitate a purchase or sale of all or part of our business; In relation to promoting the Neuroart App or Website to end users by third party business introducers; To help assess and manage risk and prevent fraud against us, our clients and fraud involving our website, mobile app or use of our service, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants; To companies that we plan to merge with or be acquired by; and To support our audit, compliance, and corporate governance functions. With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.
In addition, we may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users visit our website and services. This data will not personally identify you or provide information about your use of the Neuroart App or Website. We do not share your Personal Data with third parties for their marketing purposes without your consent.
Aggregated Data We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes.
You may exercise any of the rights described in this section before the respective Data Controller pursuant to the Legal Agreements by sending an email from your registered e-mail for Neuroart service to the respective Company providing the Service to you under the respective Legal Agreement stated below. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.
Managing Your Information You have the right to obtain the following:
Confirmation of whether, and where we are processing your Personal Data; Information about the purposes of the processing; Information about the categories of data being processed; Information about the categories of recipients with whom the data may be shared; Information about the period for which the data will be stored (or the criteria used to determine that period); Information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing; Information about the existence of the right to complain to any regulator; Where the data was not collected from you, information as to the source of the data; and information about the existence of, and an explanation of the logic involved in, any automated processing; Additionally, you may request a copy of the personal data being processed. Rectification of Inaccurate or Incomplete Information You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to your Online account).
Data Access and Portability You have the right to:
Receive a copy of your Personal Data in a structured, commonly used, machine-readable format that supports re- use; Transfer your Personal Data from one controller to another; Store your Personal Data for further personal use on a private device; and Have your Personal Data transmitted directly between controllers without hindrance. In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.
Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide the Neuroart App or Website to you, you can request that we erase your personal information and close your Account, providing your Account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevents us by law to close your account or terminate the Service. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend your Account for fraud or safety reasons, we may retain certain information from that Account to prevent that client from opening a new Account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti-money laundering and anti-terrorism financing for a period as defined under the applicable law; We may retain and use your personal information to the extent necessary to comply with our legal obligations. Because we maintain the Neuroart App or Website to protect against accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time. Withdrawing Consent and Restriction of Processing Where you have provided your consent to the processing of your personal information by us, you may withdraw your consent at any time by changing your Online account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and the verification whether our legitimate grounds override your own is pending.
Objection to Processing In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on a legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims. Please note that Data Controllers which are regulated financial institutions, such as credit institutions, e- money institutions or similar are obliged under AML laws to make risk profiling of their customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the Services, subject to all conditions for the closing of the account, specified above in this Section.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact e-mails below.
You should in the first place try to resolve the matter by sending an e-mail to the respective Data Controller under this.
Operating Globally To facilitate our global operations, we may be required to transfer, store, and process your information with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Data Protection and Confidentiality Policy. Where we transfer store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.
In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in the absence of an adequacy decision, we have – prior to sharing your information with such a corporate affiliate or a third-party service provider – established the necessary means to ensure an adequate level of Data Protection. We will provide further information on the means to ensure an adequate level of Data Protection on request.
We take the responsibility to ensure that your personal information is secure, kept in an encrypted form on servers, collocated in Special data centers. To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard non-public personal information. We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.
If you know or have reason to believe that the credentials of your Online account have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the Contact Us section below. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Online account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
We store our customers’ personal information securely throughout the life of the customer’s Neuroart account. Neuroart will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.
Can Children Use Our Services?
The Neuroart App or Website is not designed to individuals under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use the Neuroart service. If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.