NeuroBrave Platform, Products and Services Privacy Policy

Last updated: October 1^st ,2021

We at NeuroBrave Ltd. (“NeuroBrave“, “us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of our customers (“Customers“) and their personnel. This Privacy Policy describes the types of information we collect from you when you use our platform (“Platform“) and/or the services offered through the Platform (“Services“) on behalf of one of our Customers. This Privacy Policy also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at www.neurobrave.com ‘Terms of service‘ (“Terms“). “You” means any user of the Platform and/or Services on behalf of one of our Customers.

If you are an individual located in the European Union (“EU Individual“), some additional terms and rights may apply to you, as detailed herein. NeuroBrave is the data controller in respect of the processing activities outlined in this Privacy Policy. Our registered office is located at 24th Derech Chevron St., Jerusalem, Israel, 9354212

“Personal Data” means any information (“Information“) that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Policy details which Personal Data is collected by us in connection with provision of the Platform and/or Services to our Customers.

A Note for Customer’s End Users

If you are an individual using one of our Customers’ products, we may process certain Personal Data of yours on behalf of that Customer. The applicable Customer serves as a controller with respect to your Personal Data and NeuroBrave serves as a processor on its behalf. In such case, please contact the applicable Customer for information on the processing of your Personal Data.

Privacy Policy Key Points

The key points listed below are presented in further detail throughout this Privacy Policy. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Policy.

1. Information We Collect, Uses and Legal Basis. Depending on your usage, we collect different types of data and we and any of our third-party sub-contractors and service providers use the data we collect for different purposes, as specified below. You are under no legal obligation to provide us with any Personal Data. It is your voluntary decision whether to provide us with certain Personal Data, but if you refuse to provide such Personal Data, we may not be able to provide you with the Services or part thereof. We collect certain Information that you provide to us as part of registration. We also collect certain Personal Data automatically when you use the Platform and/or Services. We use your Information for various reasons, including to provide you with the Platform and Services, improve our Services, and to contact you with marketing offers. These processing activities are based on different legal bases including performance of a contract and our legitimate interests.

2. Additional Uses. We may compile statistical information based on anonymous and aggregated data we collect in order to help us understand customer needs. In addition, we use certain Personal Data for direct marketing purposes.

3. Sharing the Information We Collect. We share the Information we collect with our service providers and subcontractors who assist us in the operation of the Platform and process the information on our behalf and under our instructions. We also share your Information with the applicable Customer.

4. International Transfer. Some of our service providers and subcontractors who have access to your Personal Data are located in countries other than your own. We will ensure that we have agreements in place with such parties that ensure a similar level of privacy and data protection as set forth in this Privacy Policy.

5. Security. We implement measures aimed at protecting your Personal Data, but they do not provide absolute information security. Such measures include physical, electronic, and procedural safeguards (such as secure servers, firewalls, antivirus and SSL encryption), access control, and other internal security policies.

6. Your Rights – How to Access and Limit Our Use of Certain Personal Data. Subject to applicable law and in addition to other rights as set forth below, you may have a right to access, update, delete, and/or obtain a copy of the Personal Data we have collected about you. You also have the right to object at any time to processing your Personal Data for certain purposes, including marketing purposes. You have the right to withdraw your consent to processing, if provided, at any time by contacting us at privacy@neurobrave.com.

7. Data Retention. We retain Personal Data for as long as necessary for the purposes set forth in this Privacy Policy. We consider a number of different factors when determining the appropriate retention periods.

8. Cookies and Similar Technologies. We use cookies and similar technologies to help personalize your experience by helping save your settings and customizations across visits.

9. Error! Reference source not found.

10.

11. . We may send you email or other messages about us or our Services. You will have the opportunity to opt-out of receiving certain messages that are not service-related.

12. Children. We do not knowingly collect Personal Data from children under the age of sixteen (16).

13. Changes to the Privacy Policy. We may change this Privacy Policy from time to time and shall notify you of any material changes by indicating on the Platform that the Privacy Policy has been amended and by publishing an updated Privacy Policy on the Platform.

14. Comments and Questions. If you have any comments or questions about this Privacy Policy, or if you wish to exercise your legal rights with respect to your Personal Data, please contact us at privacy@neurobrave.com.

***

1. Information We Collect, Uses and Legal Basis. Depending on your usage, we collect different types of data and we and any of our third-party sub-contractors and service providers use the data we collect for different purposes, as specified below. You are under no legal obligation to provide us with any Personal Data. It is your voluntary decision whether to provide us with certain Personal Data, but if you refuse to provide such Personal Data, we may not be able to provide you with the Services or part thereof.

1.1. Registration Data – In order to use our Platform and/or receive related Services, you will be required to register and provide us with the following Personal Data: email address, username, and password.

How we use this data: (1) to provide you with the Platform and Services, (2) to respond to your inquiries and requests, (3) to contact and communicate with you; (4) to prevent fraud, protect the security of and address any problems with the Platform, and (5) to provide you with informational newsletters and promotional materials relating to our Platform and Services, including via email. For more information about our direct marketing activities and how you can control your preferences, please see the Direct Marketing section below.

Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you, which is considered performance of a contract with you and the applicable Customer, including responding to your inquiries and requests and providing customer support. (2) When we process your Personal Data for the purposes of preventing fraud, protecting the security of and/or addressing problems with the Platform and Services and/or for the purpose of providing you with informational newsletters and promotional materials relating to our Services, such processing is based on our legitimate interests.

1.2. Automatically Collected Data – When you visit the Platform, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as your IP address and device ID as well as your browsing history and any information regarding your browsing and usage history on our Platform only. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.

How we use this data. (1) to review usage and operations, including in an aggregated, non-specific, analytical manner, to develop new products or services and improve current content, products, and Services; (2) to prevent fraud, protect the security of our Platform and Services, and address any problems with the Platform and/or Services; and (3) to provide you with customized content, targeted offers, and advertising related to our products and Services, based on your usage history on the Platform

Legal Basis: We process this Personal Data for our legitimate interests to develop and improve our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights, and to market our own products and services.

2. Additional Uses.

2.1. Statistical Information and Analytics – We and/or our service providers use analytics tools, to collect and analyze information about the use of the Platform and/or Services, such as how often users visit the Platform, what pages they visit when they do so. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users. This helps us improve our Platform and Services, understand trends and customer needs, consider new products and services, and tailor existing products and services to customer desires. The information we collect is anonymous and we will not link it to any Personal Data. We may share such anonymous information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

2.2. Direct Marketing – As described above, we may use Personal Data to let you know about our products and Services that we believe will be of interest to you. We may contact you by email or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect your privacy rights and to ensure you have control over how we manage marketing with you:

2.2.1. We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.

2.2.2. At any time, you can update or correct your personal profile within your account or change your preferences for the way in which you would like us to communicate with you, including how you receive details of latest offers or newsletters from us.

2.2.3. You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at sales@neurobrave.com

3. Sharing the Information We Collect. We share your information, including Personal Data, as follows:

3.1. Customer. In the course of providing our Platform and Services to the Customer, we will make data about your use of the Platform, including your Personal Data available to the applicable Customer.

3.2. Service Providers and Subcontractors – We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) aid in provision of the Platform and Services and our understanding of how users are using our Platform and/or Services, including for analytics; (2) for the purpose of direct marketing (see above for more details). Such service providers and subcontractors provide us with IT and system administration services, data analysis, and provide marketing services.

3.3. Business Transfers – Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Policy.

3.4. 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 and this Privacy Policy); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; and/or (iii) as is necessary to comply with any legal and/or regulatory obligation.

3.5. 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. International Transfer.

4.1. We use subcontractors and service providers that are located in countries other than your own and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Policy, including appropriate remedies in the event of the violation of your data protection rights in such third country.

4.2. Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (“EEA“) and when required under applicable law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

4.2.1. We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.

4.2.2. Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.

4.3. Please contact us at privacy@neurobrave.com if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

5. Security. We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:

5.1. Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL (WSS and HTTPS) encryption of data.

5.2. Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need-to-know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.

5.3. Internal Policies – We maintain and regularly review and update our privacy related and information security policies.

5.4. Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.

5.5. Encryption – We encrypt the data in transit using secure data and token (JWT) encryption using RFC 7519 standard and HMAC SHA-256 algorithm protocols.

5.6. Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.

5.7. 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.

5.8. As the security of information depends in part on the security of the computer 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.

6. Your Rights – How to Access and Limit Our Use of Certain Personal Data. Subject to applicable law and certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:

6.1. Right of Access – You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.

6.2. Right to Data Portability – If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.

6.3. Right to Correct Personal Data – Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.

6.4. Deletion of Personal Data (“Right to Be Forgotten”) – If you are an EU Individual, you have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data you should also delete our app from your mobile devices, terminate your account with us, and clear our cookies from any device where you have accessed our Platform. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.

6.5. Right to Restrict Processing – If you are an EU Individual, you can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.

6.6. Direct Marketing Opt Out – You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us at privacy@neurobrave.com. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.

6.7. Right to Object – If you are an EU Individual, you can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

6.8. Right to Lodge a Complaint with Your Local Supervisory Authority – If you are an EU Individual, you may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

7. Data Retention.

7.1. Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor’s retention policy.

7.2. In some circumstances, 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. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.

7.3. Please contact us at privacy@neurobrave.com if you would like details regarding the retention periods for different types of your Personal Data.

8. Cookies and Similar Technologies. We use cookies and similar technologies for a number of reasons and to personalize the ads we serve you. Third parties through which we provide the Services and/or our business partners may be placing and reading cookies on your browser or using web beacons to collect information in the course of advertising being served on different websites. When visiting the Platform, you shall be notified of the use of and placement of cookies and other similar technologies on your device as specified herein.

8.1. What are Cookies? A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

8.1.1. A “session cookie” is temporary and will remain on your device until you leave the Platform.

8.1.2. A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.

8.1.3. First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.

8.1.4. We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.

8.2. How We Use Cookies – We use cookies and similar technologies for a number of reasons, as specified below:

8.3. Third Party Cookies – we use third party API to monitor activities on our platform and services (mixpanel.com/legal/privacy-policy/), the data being processed using the third party API does not include any Personal Data and is directed and registered using Customer anonymized number.

8.4. How to Adjust Your Preferences – Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.

8.5. By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device. Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisements that you do see will be less relevant to your interests.

9. 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.

10. Communications. We may send you email or other messages about us or our Services. You will have the opportunity to opt-out of receiving certain messages that are not service-related.

11. Children. We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has contacted us without parental permission, please advise us immediately.

12. Changes to the Privacy Policy. We may update this Privacy Policy 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. 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 Policy, we will seek to inform you by notice on our Platform or per email.

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