Privacy Policy

This privacy policy (the "Privacy Policy") explains how Neurofidelity LLC (dba Neufidelity) LLC. ("we", "our" and "us") collects, uses, stores and discloses information about users ("users", "you" and "your") through our software (the "Software"), websites, forums, blog, social media, web applications and other products and services (collectively, the "Services") or when you otherwise interact with us.

By using the Software or the Services, you accept the terms of this Privacy Policy and our terms of service (the "Terms of Service"), and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. If you have not done so already, please also review our Terms of Service. The Terms of Service contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. If you do not agree with any part of this Privacy Policy or our Terms of Service, then you may not use the Software or any of the Services.

Collection of Information

(a) Information You Provide To Us

We collect information you provide directly to us. This may include:

• (i) contact information, such as email address;
• (ii) feedback and correspondence, such as comments and "likes" you provide to our content, information you provide in your responses to surveys, when you participate in market research activities, report a problem with the Services, receive customer support or otherwise correspond with us;
• (iii) usage information, such as information about how you use the Services and interact with us; and
• (iv) marketing information, such as your preferences for receiving marketing communications and details about how you engage with them.

(b) Automatically Collected Information

When you access or use the Software or the Services, we automatically collect information about you, which may include, but is not limited to:

• (i) Log Information: We may collect log information about your use of the Software and the Services, including the type of browser you use, access times and your IP address.
• (ii) Device Information: We may collect information about the computer or mobile device you use to access the Software and our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

(c) Information We Collect from Other Sources

We may obtain information from other sources, including third parties, and combine that with information we collect through the Software and the Services.

(d) Information We Will Never Collect

We will never ask you to share your account password. Never trust anyone that asks you to disclose your password. Do not be fooled if someone reaches out to you pretending to be from us.

Use of Information

We use the information we collect to enable you to access and use and otherwise provide, maintain, and improve the Software and our Services. We may also use the information we collect to:

• (i) send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;
• (ii) communicate with you about products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you, which may be provided by any means, including by e-mail, in-app notifications, push notifications and display advertising;
• (iii) personalize your experience when you use the Software or the Services;
• (iv) administer contests, promotions, surveys and other Service features;
• (v) monitor and analyze trends, usage and activities in connection with the Software and the Services;
• (vi) comply with applicable laws, lawful requests and legal processes, including responding to court orders or requests from regulatory authorities;
• (vii) generate aggregate or de-identified data and use such data for any lawful purpose, including research and analytics; and
• (viii) detect, investigate and prevent fraudulent transactions and other illegal activities, enforce our agreements with users (including our Terms of Service) and protect our rights and property and of others.

Sharing of Information

We do not share or sell the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances:

• (i) with vendors, consultants and other service providers who need access to such information to carry out work on our behalf, including hosting, email and database services;
• (ii) in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
• (iii) if we believe your actions are inconsistent with our user agreements or policies (including our Terms of Service), or to protect our rights, property and our safety or that of others;
• (iv) in connection with, or during negotiations of, any proposed or actual merger, sale of company assets, financing, securitization, insuring, acquisition of all or a portion of our business by another company, or bankruptcy transaction or proceeding;
• (v) between and among us and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
• (vi) With your consent or at your direction.

Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Data Retention, Verification, Correction and Deletion

We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it, or for other legitimate business purposes, including to meet our legal or other regulatory obligations, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. There is no single retention period applicable to the various types of personal information collected.

You have the right to: (a) verify what Personal Information we hold about you; (b) ask for your Personal Information to be corrected or updated; and (c) withdraw your consent to the use by us of your Personal Information and have it deleted from our records. If you wish to inquire about and verify and / or correct Personal Information we hold about you, or if you wish to have all your Personal Information permanently deleted from our records, please contact us using the contact information below. Please note that deletion of your Personal Information may make it impossible for you to use the Sites or the Services, or certain portions thereof. If you request deletion of your Personal Information, we reserve the right to retain some of your Personal Information for a reasonable time to the extent it is required to be held by us by law, rule or regulation in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.

Disclaimer About Sharing Personal Information Online

You acknowledge that when sharing personal information online, there is always a risk of data breaches, including data breaches in which third parties unlawfully access our systems or the systems of our third-party providers, which store personal information.

Limitation on Liability

While we take measures to protect personal information, you agree that in no event will we, our suppliers, partners, licensors, dealers, representatives, associates or affiliates and each of their respective employees, contractors, agents, advisors, representatives, shareholders, officers and directors be liable to you or any third party for any indirect, consequential, exemplary, incidental, special or punitive damages, including lost profit damages arising from your use of the Software or the Services, even if we have been advised of the possibility of such damages. Notwithstanding anything to the contrary contained herein, our liability to you for any cause whatsoever and regardless of the form of the action, will at all times be limited to the amount paid, if any, by you to us during the six (6) month period prior to any cause of action arising.

GDPR Compliance

If you are located in the European Economic Area ("EEA"), you have certain rights under the General Data Protection Regulation ("GDPR"). These rights include:

• The right to access your personal data
• The right to rectification of inaccurate personal data
• The right to erasure of your personal data
• The right to restrict processing of your personal data
• The right to data portability
• The right to object to processing
• Rights related to automated decision-making and profiling

To exercise any of these rights, please contact us at info@neufidelity.com. We will respond to your request within 30 days.

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority. You can find contact information for data protection authorities in the EEA at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm

California Privacy Rights

If you are a California resident, you have certain rights under the California Consumer Privacy Act ("CCPA"). These rights include:

• The right to know what personal information we collect, use, disclose, and sell
• The right to request deletion of your personal information
• The right to opt-out of the sale of your personal information
• The right to non-discrimination for exercising your CCPA rights

To exercise any of these rights, please contact us at info@neufidelity.com. We will verify your identity before processing your request.

International Data Transfers

Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there.

Third-Party Services

The Software and Services may contain links to third-party websites, applications, and services. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of every website, application, and service you visit or use.

Changes to this Privacy Policy

We may change this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms. In all cases, your continued use of the Software or the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Our Policies for Children

Our products, the Software and the Services are only directed to persons of the age of 18 or over. We do not knowingly collect any personal information from individuals under 18. If we become aware that we have unknowingly collected personal information from an individual under the age of 18, we will make commercially reasonable efforts to delete such personal information from our records. If you are concerned and are aware of a user under the age of 18 using our the Software, the Services or our products, please contact us by contacting us as indicated in the "Contact Us" section below.