PRIVACY POLICY

Effective as of September 29, 2020

 

This Privacy Policy is designed to help you understand how Neurocore, LLC (“Neurocore”), Neuropeak Pro, LLC (“Neuropeak Pro”), and their related organizations and affiliates (collectively, “we”, “us” or “our”) collect, use and disclose personal information you share with us. 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 OUR SERVICES, YOU 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 OUR SERVICES OR PROVIDE US WITH YOUR INFORMATION.

This Privacy Policy is designed to help you understand how Neurocore, LLC (“Neurocore”), Neuropeak Pro, LLC (“Neuropeak Pro”), and their related organizations and affiliates (collectively, “we”, “us” or “our”) collect, use and disclose personal information you share with us. 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 OUR SERVICES, YOU 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 OUR SERVICES 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 www.neuropeakpro.com, www.neurocorecounseling.com,or www.neurocore.com (the “Sites”), (b) fill out intake forms or assessment questionnaires, (c) participate in our services, including those branded as Neurocore or Neuropeak Pro, and (d) receive our communications or participate in our events. 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 our Neuropeak Pro services. For information about Myndlift’s privacy practices, please review Myndlift’s Privacy Policy. Specifically, this Privacy Policy covers the following topics:

 

PERSONAL INFORMATION WE COLLECT

 

HOW WE USE YOUR PERSONAL INFORMATION

 

HOW WE SHARE YOUR PERSONAL INFORMATION

 

YOUR CHOICES

 

COOKIE POLICY

 

OTHER IMPORTANT PRIVACY INFORMATION

 

NOTICE TO CALIFORNIA RESIDENTS

 

COLLECTION NOTICE

 

HOW TO CONTACT US

 

CHANGES TO THIS 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, and payment information.

· Feedback and correspondence. We collect information about you when you request information, respond to surveys, or otherwise correspond with us.

· Client intake. We collect additional information about you, such as your race, gender, and information about your wellbeing, through our client intake process.

· Training and evaluation. We may collect information about you when you participate in our training program and interact with our coaches or otherwise engage in our service offerings.

· 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 Sites, such as your Internet Protocol (IP) address, device and browser type, operating system, DNS, the pages or features of the Sites that you browsed and the time spent on those pages or features, the frequency with which you use the Sites, 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.

 

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 Sites;

· to better understand your needs and interests, and personalize your experience with the Sites;

· to provide you with our training services;

· to register you for training sessions;

· to respond to your requests, questions, comments, feedback, and training results; and

· to perform website 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, you must create an account using certain personal information, including your name and email address. You have choices about the information included in your account profile. You do not have to provide additional information on your profile; however, additional profile information may help you get more from our services. It is your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile 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 Sites 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 Sites, 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 Sites 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 Sites 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 Sites, provide services to support the Sites, 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. Neuropeak Pro is a wholly-owned subsidiary of Neurocore. Neurocore and Neuropeak Pro may share your personal information between us as well as among our other affiliates and related organizations, for use consistent with this Privacy Policy.

 

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. Currently, we use Myndlift to provide our training application. Personal information gathered through the Myndlift app is subject to Myndlift’s Privacy Policy. A list of our other current service providers is available upon request.

 

Business Partners. We may share your personal information with our business partners who offer a service to you jointly with us. A list of our current business partners that have access to certain personal information we collect 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 following sections: For compliance, fraud prevention and safety and for compliance with law.

 

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 email notifications by sending a request via email to clientengagement@neuropeakpro.com.

 

Opt Out of Marketing 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 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 Sites 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 Sites, including strictly necessary cookies, which are cookies that are necessary for the Sites 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 Sites; and functional cookies, which enable the Sites to provide enhanced functionality and personalization. Specifically, the cookies we use are:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.

 

If you sign up to receive our e-mails, we will also use cookies in conjunction with these emails. When your browser downloads any graphic content in the e-mail, we will also place a cookie on your computer that will tell us if you come to our website at a later date.

 

Third-Party Cookies. In addition to our own cookies, we collaborate with various third-party service providers who also use cookies to help us optimize our website, provide ads to our customers, and understand more about the visitors to our website. Our third-party service providers include: Amazon Web Services, Cloudflare, Facebook, Google Analytics, LinkedIn, Microsoft, Pardot, Wistia, and Wix. To learn more about how these providers use cookies, please click the links above or visit their respective websites to view their cookie policies.

 

How Can You Disable Cookies and Other Tracking Technology? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
 

Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

 

Google Services

We use Google Analytics to help us gather statistical information about the visitors to our Sites and to market our services. Specifically, we use Google Ads remarketing technology to market our services throughout the Internet, but only if you have turned on Ads Personalization through Google. We also use Google Analytics to help us gather statistical information about the visitors to our Sites and how they use the Sites on an anonymous, aggregate basis. We may use this information to gain a better understanding of the users of our Sites, to improve our Sites, and to improve our services. We will not associate any data we gather through Google Analytics with your personally identifiable data unless required to do so to cooperate with law enforcement or other governmental request or to comply with law. To understand how Google Analytics collects and processes data, please visit Google’s Privacy Policy.

 

Google Analytics relies on cookies. In addition to controlling cookies generally as described above, you may have the ability to specifically control the type of information that Google Analytics uses. You can opt-out of Google Analytics by visiting the Google Ads Preferences Manager. In addition, to provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on, to enable you to opt-out of Google’s programs.

Other Important Privacy Information

 

Health Information.

If you are receiving Neurocore clinical services, Neurocore may collect certain health information about you. Details about how Neurocore collects, uses and discloses your health information is available at https://www.neurocorecenters.com/privacy-policies.

 

Third Party Sites and Services.

The Sites 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 as detailed below 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 Sites are 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 Sites 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 Sites 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 Sites.

 

 

Notice to California Residents

 

The following section applies to California residents.

 

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. To make a request please contact us as instructed in the “How to Contact Us ” section and specify you are making a Shine the Light request.

 

California Consumer Privacy Act (“CCPA”). The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.

 

Personal Information We Collect. We collect your personal information when you interact with our Site or otherwise communicate with us. For the purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.

 

We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:

 

Category of Personal Information Collected Business Purpose of Collection

Identifiers, including real name, alias, signature postal address, unique personal identifier, online identifier, Internet Protocol address, email

address, account name, telephone numbers.

Information about children, including name, age, and gender.

Characteristics of protected classifications under California or federal law, including age or date of birth, physical disabilities, mental disabilities,

medical condition, and sex.

Occupation, professional, or employment-related information.

Medical information, including medical condition; drugs, therapies, or medical products or equipment used; health insurance information; insurance policy numbers.

Financial information, including credit or debit card number or debit card number.

Biometric information.

Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an Internet Web site, application or advertisement.

Geolocation Data.

Audio information.

Any inferences drawn from the information identified above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

Business Purpose of Collection

To provide you our services, collect payment for our services, and communicate with you. In addition, we collect your IP address anonymously to provide you more relevant content, track original Site visits, and optimize your Site experience.

 

 

We collect this information only if we are providing our services to a minor child.

To provide our services, specifically for evaluation and program development.

If you are referred by a company or management team, or if we are providing services intended to optimize performance related to your profession.

To inform evaluation data collection and feedback Any information collected in this category by Neurocore is subject to HIPAA and addressed in our Notice of Privacy Practices rather than this Privacy Policy.

 

To bill you for our services.

For service evaluation.

To provide you more relevant content, track original Site visits, and optimize your Site experience.

We collect anonymous general location data (city, state, country) about our Site visitors for analytics purposes.

Calls to our 800 number are recorded for quality assurance and training purposes with your consent.

To provide our services, specifically for evaluation and program development.

 

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.

 

Sharing Your Information. We do not sell your personal information, but we may disclose it to third parties for a business purpose. Specifically, we disclose the following categories of personal information covered by the CCPA for a business purpose:

 

 

Category of Personal Information Collected 

Identifiers, including real name, alias, signature postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone numbers.

Financial information, including credit or debit card number or debit card number.

Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an Internet Web site, application or advertisement.

Geolocation Data Data analytics providers.

Audio and visual information.

 

Category of Third Parties with Whom Information is Disclosed

Service providers, including our customer relationship management (CRM) solution providers, Site service providers, data analytics providers, and social networks.

 

Third party payment proessors.

 

Data analytics providers, marketing service providers.

Audio information is shared with our CRM solution providers.

 

Please note that we may collect, use and share additional personal information about you that is governed by laws other than the CCPA, and that our activities related to such personal information are not disclosed here. If you are receiving Neurocore clinical services, health information collected by Neurocore is one such example. Details about how Neurocore collects, uses and discloses your health information is available here.

 

Source of Personal Information. Our Privacy Policy contains more comprehensive details about the sources from which we obtain your personal information. To read this more detailed disclosure, see the section entitled “Personal Information We Collect” above. More broadly, we obtain the categories of personal information that are listed above in the following ways:

 

Directly from You. For example, when you:

• Create an account.

• Fill out our questionnaires.

• Pay for our services

• Sign up to receive promotional emails or text messages.

• Provide your contact information to us.

• Submit a request to us.

• Participate in one of our surveys.

• Interact with our social media pages.

 

We collect the following categories of personal information directly from you: identifiers, including your name, postal address, user name, email address, and telephone number; information about children; characteristics of protected classifications; occupation, professional, or employment-related information;

medical information; and financial information.

 

Passively. For example, when you:

• Visit and navigate our Site on any device.

• Click on sponsored links or third-party advertisements.

• Receive or interact with our communications and Site that may contain cookies.

• Contact use via our 800 number.

• Use our Services.

 

We collect the following categories of personal information directly from you: IP address, Internet or other electronic network activity information, geolocation data, biometric data, and audio information.

 

From Third Parties. We may receive information about you from other sources. For example, we get information from:

• Our service providers, including Myndlift

• Our business partners, including online advertising networks.

• Social media platforms, including Facebook and LinkedIn.

 

We collect the following categories of personal information from third parties: IP address, Internet or other electronic network activity information, biometric data.

 

Your Rights. The CCPA gives you certain rights regarding your 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 Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.

 

Exercising Your Rights. To exercise your rights above, please submit a request to us at https://www.neuropeakpro.com/ccpa or contact us using one of the methods set forth in the “How to Contact Us” section below. 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.

 

 

How to Contact Us

 

201 Monroe Ave NW, Suite 300

Grand Rapids, MI 49503

United States of America

Phone: (800) 600-4096

 
 
 
 
 
 
 

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