NeuroBrave Sense Mobile B2B App Privacy Notice

Last updated: June 2025

This Privacy Notice provides you with information about what Personal Data we collect about you, how and why we use it, with whom we share it, how we store it, and how you can control our processing of your data. This Privacy Notice is meant to be read together with our Terms of Service, which you can find at Neurobrave Sense Terms of Service.

We at NeuroBrave Ltd. (“us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of the users of our App. Our App (“App“) offers tools for personal wellness and well-being, including reports, stress management, and mindfulness exercises (“Exercises“) (such tools and services, together with the App, the “Services“). “You” means an individual using the Services by yourself, or in connection with an organization with which you are affiliated or of which you are a member (“Customer“), who has signed a separate agreement with us in connection with the Services (“Customer Agreement“).

“Personal Data” means any information that refers to, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data we collect when we provide our Services to you. This Privacy Notice describes the types of Personal Data we collect from you when you use our Services.

1.      Information We Collect

1.1.   Sensor Data.

1.1.1. Accelerometer Data: Collected via Bluetooth from a connected wearable to monitor motion.

1.1.2. Optical Heart Rate Sensor Data: Collected via Bluetooth for real-time physiological monitoring and biofeedback.

1.2.   Permissions Notice and Location Data. Location Permission is required due to operating system Bluetooth scanning restrictions. We do not collect, store, or transmit Geo-location data or GPS data.

1.2.1. For Android devices: Our app requests location access solely to support Bluetooth Low Energy (BLE) device connectivity. Android requires location permission to detect and connect with nearby BLE devices. This permission is used exclusively to enable Bluetooth communication with your paired devices.

1.2.2. For iOS devices: Our app uses your location only to enable communication with Bluetooth Low Energy (BLE) devices. In iOS, location access is required by the system when scanning for nearby BLE peripherals. The permission is used strictly for connecting with supported Bluetooth devices.

1.3.         Time Zone Information. Used to provide accurate time-based insights and user interface updates.

1.4.         Exercises. When using our Services, we collect information regarding your engagement with the Exercises, including which Exercises you perform, the frequency of your usage, and the effectiveness of these Exercises.

1.5.         Materials You Upload. We also collect any materials you may upload to the App or questionnaires while using the App or the exercise program.

1.6.         Activity and System Data (Cookies). When you use the App, we may gather certain information automatically about your device, such as your operating system, device ID, and subject to your consent as may be required under applicable law, usage data, metadata.

2.      How We Use Your Personal Data

2.1.         General. We and any of our trusted subcontractors and service providers use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Services, including the daily and weekly reports; (2) to respond to your inquiries or requests, contact and communicate with you, and provide customer support; (3) to develop new products or services and conduct analyses to improve our current Services; (4) to review the usage and operations of our App and Services; (5) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (6) to prevent fraud, protect the security of our App and Services, and address any problems with the App and/or Services.

2.2.         Statistical Information and Analytics. We and/or our trusted service providers use analytics tools to collect and analyze information about the use of the Services, such as how often users visit the App. This helps us improve our Services, which in turn allows us to consider new products and services or tailor existing products and services accordingly. We may share such anonymous information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

3.      Sharing the Personal Data We Collect. We do not share your information, including Personal Data, with any third party unless we are required and enforced by law as follows:

3.1.         Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms, the Customer Agreement and this Privacy Notice); (ii) as is necessary to comply with any legal and/or regulatory obligation; or (iii) when required by subpoena, court order or the order of another governmental or law enforcement authority.

3.2.         Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

4.      Security. We make efforts to follow generally accepted industry standards and above, to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the device you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

5.      Your Rights. Subject to applicable law, you may request to see any Personal Data you have provided to us and request that such Personal Data be corrected, updated, or deleted by emailing us at support@neurobrave.com, or using our Data Deletion Guide.

6.      Data Retention Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above and then delete the Personal Data once we deem it no longer necessary for these purposes. In some circumstances, however, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

7.      Cookies and Similar Technologies. We use cookies and similar technologies for a number of reasons, including to help personalize your experience. When visiting this App, you are hereby notified of the use and placement of cookies and other similar technologies on your device as specified herein.

7.1.         How We Use Cookies/System Logs. We use cookies and similar technologies for a number of reasons, as specified below.

The specific names and types of the cookies, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

7.2.         How to Adjust Your Preferences. Please contact us at support@neurobrave.com, and we will do our best to adjust the System Logs to your preferences.

8.      Third-Party Applications and Services. All use of third-party applications or services is at your own risk and subject to such third party’s terms and privacy policies. We do not take any responsibility for the performance of other services.

9.      Communications. We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account.

10.     Children. We do not knowingly collect Personal Data from children under the age of eighteen (18), unless we receive a specific request and a signed approval of the responsible parent or guardian. In the event that you become aware that an individual under the age of eighteen (18) has enrolled without parental permission, please advise us immediately.

11.     Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage or other official company public information channels. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by a notice on our App or via email.

12.   Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at support@neurobrave.com.