Last updated: January 1, 2023.
This Privacy Policy is designed to help you understand how Neuropeak Pro, LLC (“Neuropeak Pro”) and its related organizations and affiliates (collectively, “we”, “us” or “our”) collect, use and disclose personal information you share with us through our websites and mobile applications. We value your privacy, and we will not share your personal information with third parties except as described in this Privacy Policy without your consent.
BY USING THIS SITE OR OUR SERVICES, YOUR AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THE PRIVACY POLICY,PLEASE DO NOT USE THIS SITE OR PROVIDE US WITH YOUR INFORMATION.
What this Privacy Policy Covers
This Privacy Policy applies to our collection, use and sharing of your personal information when you: (a) visit our websites at neuropeakpro.com, and its related sites and applications including the Neuropeak Pro mobile application (collectively, the “Site”), (b) fill out forms or questionnaires, (c) participate in our services, and (d) receive our communications or participate in our events and challenges. It also applies to your personal information that we obtain from third parties such as resellers, database vendors, content publishers and suppliers. This Privacy Policy does not apply to any other information, websites or services not owned or operated by us, including the Myndlift application, which we use to provide certain Neuropeak Pro training services. For information about Myndlift’s privacy practices, please review Myndlift’s Privacy Policy.
Personal Information We Collect
Information You Give Us. Personal information you may provide through a Site or otherwise communicate to us includes:
- Contact information. We collect information about you when you provide contact information to us via email, mail, or through a Site, including as a result of creating an account, completing a form to request more information about our services, or scheduling services. This information may include your first and last name, email address, mailing address, phone number, payment information, and geolocation.
- Feedback and correspondence. We collect information about you when you request information, respond to surveys, or otherwise correspond with us.
- Training and evaluation. We may collect information about you when you participate in our training programs and services
- Other information. We may collect other information from you that is not specifically listed here. We may use such information in accordance with this Privacy Policy.
Information We Get From Others. We may obtain additional information about you from third party sources, such as service providers, vendors, social media sites, and advertising agencies to provide you with more relevant information about our services.
Information Automatically Collected. Our servers and third party service providers may automatically record certain information about how you use the Site, such as your Internet Protocol (IP) address, device and browser type, operating system, DNS, the pages or features of the Site that you browsed and the time spent on those pages or features, the frequency with which you use the Site, the links that you click on or use, and other statistics. We collect this information in server logs and by using cookies and similar tracking technologies. See our Cookie Policy, below, for more information.
Statistical Analyses. We use Google Analytics to help us gather statistical information about the visitors to our Site and how they use the Site on an anonymous, aggregate basis. However, we will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law. We may use this information to gain a better understanding of the users of our Site, to improve our Site, and to improve our services. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics use. To understand how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners/. We reserve the right to license or sell aggregate, de-identified information about the visitors to our Site, but this information will not contain your personal information or otherwise be individually identifiable.
How We Use Your Personal Information
We use your personal information for the following purposes and as otherwise described to you in this Privacy Policy or at the time of collection:
To Provide our Services and Communicate With You. We use your personal information:
- to provide, maintain and improve the Site;
- to better understand your needs and interests, and personalize your experience with the Site;
- to register you for and provide you with our services;
- to respond to your requests, questions, comments, and feedback; and
- to perform Site analytics and database management services.
To Send You Marketing Communications. We may send you newsletters, promotions or other marketing communications, but you may opt out of receiving them as described in the “Your Choices” section below.
To Create and Maintain Your Account. To utilize any of our services provided through our mobile application, you must create an account using certain personal information, including your name and email address. You have choices about the information you provide in the mobile application. You do not have to provide additional personal information; however, additional information may help you get more from our services. Please do not share or add personal data in the mobile application that you would not want to be publicly available.
To Advertise To You. We may use your personal information to manage and serve ads in the Site or on third party sites and to tailor ads to your interests and browsing history. In addition to the cookies utilized by us on our Site, we may allow trusted third parties to place advertisements for our services on sites and applications operated by others. These third parties may use cookies and web beacons to measure the effectiveness of our ads and to determine the display of content and advertising to you based on your interests both on our Site and other sites and applications that you may visit (see our Cookie Policy below). To support this interest-based advertising solution, we and the companies we have contracted with may use anonymous information about your visits to our and other websites and applications. The information collected and used by this process is always anonymous and does not enable any third party to identify you individually. You can learn more about interest-based advertising and opt out of such advertising from certain companies at aboutads.info.
For Compliance, Fraud Prevention and Safety. We may use your personal information as we believe appropriate to: (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our Site for illegal reasons.
With Your Consent. In some cases we may ask for your consent to collect, use or share your personal information.
How We Share your Personal Information
We may use third parties to help us design and operate the Site, provide services to support the Site, process your information, provide our services, and provide promotional and marketing activities on our behalf. For example, we may hire a company to run certain website applications, help us analyze your data, or send information on our behalf about services and events in which you may be interested. Unless otherwise indicated at the time we collect your information, if we allow third parties to access the personal information we collect, we will have contractual provisions or other appropriate protections in place to ensure such access is for limited purposes and in compliance with this Privacy Policy. We do not share your personal information with third parties without your consent, except as described in this Privacy Policy.
Related and Affiliated Organizations. We may share your personal information with our affiliates and related organizations, for use consistent with this Privacy Policy.
Your Team Leaders. If you are participating in a Neuropeak Pro NTEL BELT training team, we will share your personal information with your team leaders. This information will include your name, biometric information for each training session, and analysis of this biometric information for each session and across multiple sessions (collectively, “Session Data”).
Service Providers. We may share your personal information with third party companies and individuals as needed for them to provide us with services that help us with our business activities and to promote our services to you. For example, we use Myndlift to provide our neurofeedback training services. Personal information gathered through the Myndlift app is subject to Myndlift’s Privacy Policy. A list of our other current service providers and business partners is available upon request.
Business Partners. We may share your personal information with third party companies and individuals who offer a service to you jointly with us and those you authorize to access your Session Data via Application Programming Interfaces (API). A list of our other current business partners is available upon request.
Security, Compliance, Fraud Prevention, Safety; Compliance with Law. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the section titled “For compliance, fraud prevention and safety.”
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.
Your Choices
Opt Out of Communications. You may opt out of marketing-related emails by following the opt-out prompt in the email. To opt out of other forms of marketing communications, please send a request via email to [email protected] or contact us using the contact information provided at the end of this Policy.
Consequences of Not Providing Personal Information. You are not required to provide all personal information identified in this Privacy Policy to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we will not be able to successfully provide our training services, and we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
Cookie Policy
What are Cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies”. Cookies set by parties other than the website are called “third party cookies”. Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
What Cookies and Other Tracking Technologies do We Use? We use several different kinds of cookies on our Site, including strictly necessary cookies, which are cookies that are necessary for the Site to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Site; and functional cookies, which enable the Site to provide enhanced functionality and personalization. Specifically, the cookies we use are:
Other Important Privacy Information
Third Party Site and Services: The Site may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more. Security. The security of your personal information is important to us. We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information. International Data Use. We are located in the United States and have affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. Verifying, Changing, and Deleting Your Information. You can contact us at [email protected] or as detailed at the end of this Privacy Policy and ask us to change, update or fix your information in certain cases, particularly if it is inaccurate. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information). Children. The Site is not intended for use by anyone under the age of 13, nor do we knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, you should not attempt to use the Site or send any information about yourself to us.Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy we will post them on the Site and indicate the effective date of the change. If we make material changes to this Privacy Policy we will notify you by email or through the Site.Location-Specific Disclosures
The law requires that we provide additional disclosures to residents of certain countries, regions and states. Please see below for disclosures that may be applicable to you.Notice to European Users
The following applies to individuals in the European Economic Area and United Kingdom. Controller. Neuropeak Pro, LLC is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. Legal bases for processing. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us using one of the methods detailed at the end of this Policy.Retention. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us as detailed at the end of this Policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfers. Any information you provide to us through the use of the Site may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is kept. Regarding transfers from the European Economic Area (“EEA”) and United Kingdom to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions outside the EEA or United Kingdom, your use of the Site or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed below.
Notice to California Residents
The following section applies to California residents.
Personal Information We Collect. We collect your personal information when you interact with our Site or otherwise communicate with us. We have collected the following categories of personal information from consumers through the Site within the past 12 months, and have used it for the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
Retaining Your Information. We will only keep your personal information in an accessible form which can identify you for as long as we need to for the purposes for which it was collected. Because retention periods vary depending on the purpose for collection, we use certain categories and criteria to determine how long we keep personal information, as further described below. Where your personal information is used for more than one purpose, we will retain your Information for the longer of those periods.
When we no longer require your personal information, we will take steps to delete or anonymize it. If the information cannot be permanently deleted or anonymized (for example when it is stored in our electronic backups), we will take appropriate steps to ensure that it is: (a) not used in connection with any decision involving you; (b) not shared with anyone except when we are legally required to do so; (c) kept secure; and (d) permanently deleted once possible.
Sharing Your Information. We do not share your personal information with third parties for cross-context behavioral advertising purposes or otherwise sell your personal information, but we may disclose your personal information to third parties for a business purpose. Specifically, we disclose the following categories of personal information to subcontractors and service providers for a business purpose:
We may also share certain personal information with third parties at your direction. For example, if you are participating in a Neuropeak Pro NTEL BELT training team, we will share your Session Data with your team leaders. You may also ask us to share your Session Data and other account information with third parties for their own services, including via API.
Source of Personal Information. We obtain the categories of personal information that are listed above in the following ways:
- Directly from You. We collect identifiers; characteristics of protected classifications; occupation, professional, or employment-related information; and financial information directly from you when you provide your information to us or submit a request to us.
- Passively. We collect IP addresses, internet and other electronic activity information, geolocation data, biometric information and audio information from you when you visit and navigate our Site on any device, click on sponsored links or third-party advertisements, contact us via phone, or receive or interact with our communications and website that may contain cookies.
- From Third Parties. We may receive IP address, Internet or other electronic network activity information, and biometric data about you from other sources. For example, we get information from: our business partners, including online advertising networks; social media platforms; and service providers, including Myndlift.
Sensitive Personal Information. We do not use or disclose sensitive personal information except as necessary to provide you with our services.
Personal Information of Children. We have no actual knowledge that we sell or share personal information of consumers under 16 years of age.
Your Rights. California residents have certain rights with respect to their personal information:
- Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
- Right to Correct. You may request that we correct inaccurate personal information we maintain about you.
- Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
- Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes.
Exercising Your Rights. To exercise your rights above, please submit a request to us at https://neuropeakpro.com/ccpa or contact us using one of the methods detailed at the end of this Privacy Policy. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide your name and email address. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request. After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. You may also make a request on behalf of your minor child. We may not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
Notice to Nevada Residents
Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties. We do not sell your personal information for monetary consideration; however, this right still applies. If you are a Nevada consumer and wish to exercise this right, please submit your request by contacting us as detailed at the end of this Privacy Policy.
Notice to Virginia Residents
If you are a Virginia resident, this section applies to you in addition to the rest of this Privacy Policy.
We collect the following categories of personal data from consumers when you interact with our Site or otherwise communicate with us:
We will not process additional categories of personal data or use the personal data we processed for materially different, unrelated, or incompatible business purposes without providing you notice. If we process personal data that is considered “sensitive data” under Virginia law, we will only do so in connection with our services and we will obtain your consent before we process this data. We will only retain your information as long as it is reasonably necessary for the purposes for which it was processed.
Sharing Your Data. We may share some of your personal data with third parties. Specifically, we share the following categories of personal data with third parties:
Your Rights. Virginia law gives you certain rights regarding your personal data:
- Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal data we have processed.
- Right to Correct. You may request that we correct inaccurate personal data we maintain about you.
- Right to Delete. You may request that we delete certain personal data we have collected about you, with certain exceptions.
- Right of Access. You have the right to request a copy of the personal data we have collected from you, and under certain circumstances to receive a copy of such personal data.
Exercising Your Rights. To exercise your rights above, please contact us as described at the end of this Privacy Policy. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide your name and contact information. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request. After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal data.
Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason and the extension period. We will deliver our written response by mail or electronically, at your option. Our response will also explain the reasons we cannot comply with any request, if applicable. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request. You have the right to appeal our refusal to take action on a rights request within 30 days after receiving our decision by contacting us as detailed at the end of this Privacy Policy. We will try to inform you of our decision in writing within 60 days after receipt of your appeal, with a written explanation of our decision.
How to Contact Us
Neuropeak Pro, LLC
201 Monroe Ave NW, Suite 300
Grand Rapids, MI 49503
United States of America
Phone: (800) 600-4096
