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Neurosmart Privacy Policy

Last Updated 10-Dec-2025

1. Introduction

 

Neurosmart, a Delaware C Corporation, is committed to protecting your privacy and safeguarding data collected through the Neurosmart App. This Privacy Policy describes what information we collect, how we use it, and how we protect it. By installing or using the App, you agree to this Policy.

2. Scope

 

This Privacy Policy applies to all data processed through the Neurosmart App including data transmitted by Neurosmart wearable devices and analytics generated by NeuroLytics™. It does not apply to data collected outside the Neurosmart system or by third parties.

3. Information We Collect

 

We do not collect personally identifying information unless you explicitly provide it.

 

With your consent, the App may collect:

  • Sensor data from Neurosmart devices

  • Optional user notes or annotations

  • Non-identifying diagnostic or usage data

4. How We Use Data

 

Data is processed by NeuroLytics™ to generate insights such as stress indicators, resilience metrics, and performance analytics. All stored data is de-identified. We do not store or associate your name or identity with the data.

5. Data Storage and Security

 

We use commercially reasonable security measures including encryption, secure data transmission, and tightly controlled access. Only authorized Neurosmart personnel may access anonymized data for support or analytics.

​​​6. User Consent and Controls

 

You control what data is collected. You may withdraw consent at any time by uninstalling the App or disabling optional features. You may request access to or deletion of your data by contacting privacy@neurosmartinc.com.

​7. Use of NeuroLytics Data

 

You may use NeuroLytics™ output in reports or presentations if you cite Neurosmart as the source.

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Example attribution: “Source: Neurosmart NeuroLytics Analytics.”

8. No Sale or Sharing of Personal Data

 

Neurosmart does not sell, rent, lease, or trade personal data. Any shared datasets are anonymized and aggregated.​

9. Children’s Privacy

 

The App is not intended for individuals under the age of 18. We do not knowingly collect data from minors.

10. Third-Party Services

 

The App does not share data with third-party advertisers or analytics services. Any future additions will include revised notices and require user consent.

11. Changes to This Privacy Policy

 

We may update this Privacy Policy over time. Updated versions will be posted on our website and within the App. Continued use signifies acceptance of updated terms.

​​​12. GDPR Notice: Data Protection Summary for Users in the European Union


This notice is provided to individuals in the European Union, the European Economic Area, the United Kingdom, and Switzerland to comply with applicable data protection laws including the General Data Protection Regulation (GDPR).

 

Neurosmart, Inc. acts as the data controller for personal data processed through the Neurosmart App unless stated otherwise in a separate institutional agreement.

 

Types of Data Collected (only with user consent):

  • Biometric or physiological data generated by Neurosmart wearable devices

  • Optional user-entered notes or annotations

  • Optional diagnostic or usage data

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Anonymized and aggregated analytics generated by NeuroLytics™ Legal Basis for Processing:

  • Your consent

  • Performance of a contract

  • Legitimate interests such as product safety, performance, and diagnostics

 

Your GDPR Rights:

  • Access your data

  • Correct inaccurate data

  • Request deletion

  • Restrict or object to processing

  • Data portability

  • Withdraw consent at any time

 

Data Transfers:

Your data may be transferred to servers in the United States. Neurosmart uses safeguards including encryption, strict access controls, and Standard Contractual Clauses.

 

Automated Decision-Making:

We do not use automated decision-making that has legal or significant effects on App users.

13. California Privacy Notice (CCPA/CPRA)

 

This section applies to residents of California.

 

Categories of Personal Information Collected:

The Neurosmart App does not collect personal identifiers such as name, email, address, or phone number unless you provide such information under a separate agreement.

 

We may process the following categories only if you opt in:

 

  • Physiological or biometric sensor data

  • Non-identifying usage or system performance data

 

Anonymized analytics created by NeuroLytics™ California Consumer Rights:

 

  • The right to know what personal information is collected

  • The right to request deletion

  • The right to correct inaccurate information

  • The right to opt out of data sale (Neurosmart does not sell data)

  • The right to limit use of sensitive personal information

  • The right not to be discriminated against for exercising privacy rights

 

Sensitive Personal Information:​

Biometric or physiological data is anonymized unless you separately provide identifying information.

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No Sale of Personal Information:

Neurosmart does not sell, rent, or trade any personal data.

14. Contact Information

 

For questions or privacy-related requests, contact:privacy@neurosmartinc.com

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