This privacy notice is meant to give you information about what personal data we collect about you, how we use it, why we use it, and how you control the data processing.
1. The basics
Who we are
Neuro-Technology Solutions Ltd. offers services which can assist in diagnostic activities relating to Attention Deficit Hyperactivity Disorder and is provided through our website. Our offices are located at Kohav Ha-Yam 80 Hofit, Israel, and our registration number is 514105287.
If you have questions about our company or your privacy, or want to exercise your rights you can contact us at privacy@neurotek.ai.
Our role: controller and processor. Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a “controller”) and a party that processes personal data solely on the controller’s behalf and according to the controller’s instructions (called a “processor”). We are the controller in respect of the processing described in this privacy notice. That said, in respect of certain personal data, we serve as a processor. Please see the section below on personal data we collect as a processor for more information.
Definitions and recommendations
When we refer to “services”, we mean the services which can assist in diagnostic activities relating to Attention Deficit Hyperactivity Disorder (ADHD) and is provided through Neurotech’s website https://moxo.ai/, including the proprietary MOXO™ d-CPT Test (“Assessment”) and the Reports (as defined in the Terms of Service).
When we refer to “personal data”, we mean information that is defined as personal data under law. This includes information that identifies you directly or indirectly, including unique identifiers like IP addresses or cookie IDs.
When we refer to “you”, we mean any Customer and/or Permitted User and/or any Participant and/or their parent and/or legal guardian. When we refer to “Customer”, we mean any institution, clinic, healthcare facility or other such entity using the services. When we refer to “Permitted User”, we mean an employee or colleague designated by a Customer to access the services. When we refer to “Participant”, we mean the individual taking the Assessment.
This privacy notice is meant to be read together with our Terms of Service, which you can find at https://moxo.ai/terms-of-service/. In general, we recommend that you routinely review this privacy notice and your preferences on our site.
A note on legal bases. Certain jurisdictions only allow the processing of personal data where a legal basis has been established. Under the EU’s General Data Protection Regulation (“GDPR”), the possible legal bases include: your consent, the processing is necessary to perform a contract with you, the processing is necessary to fulfill our legal obligations, or a company has a legitimate business interest to process your personal data. Where we are a controller, we only collect and process data where we have established a legal basis.
2. Personal data we collect as a controller, how we use it, and why
Below is a description of the types of personal data we collect, how we use it, and the reason why we consider each use lawful. You have no legal obligation to provide us with personal data, but if you don’t provide us with certain information, we may not be able to provide you with the associated services.
2.1 Website visitors
Contact form information. When you send us a message through the contact form on our site, we collect any data you provide, such as your name, profession, email, phone number, country of residence and the content of your message. When you sign up for our newsletters, we collect your email address. How we use this data: to respond to your message and to provide you with informational newsletters about our products and services, and provide you with promotional materials we think may be of interest to you. Legal basis: we process this personal data based on your consent. You may withdraw your consent at any time by emailing us at privacy@neurotek.ai.
Activity and system data (automatically collected, including through cookies). When you visit our site, we automatically collect data about your computer or mobile device, including personal data such as your IP address, device ID, browsing history, and your activity on our site, including through the use of cookies and similar technologies. How we use this data: we mainly use this data to generate aggregated analytics data about the use of our site so we can maintain and improve the site and develop new products or services. We also use statistical data to prevent fraud and protect the security of our site. Legal basis: when we process this personal data which is generated from cookies for the purpose of developing and improving our services, we do so based on your consent. When we process this personal data which is not generated from cookies, and/or for the purpose of preventing fraud, we do so based on our legitimate interests. You may withdraw your consent at any time by emailing us at privacy@neurotek.ai.
2.2 Users
Registration data. In order to access our services, you must first create an account. When creating an account, you will be asked to provide us with personal data, such as your name, address, phone number, e-mail address, job function, professional license number (if relevant), degree, and country of residence. If you access our platform using a third-party login service (such as Apple, Microsoft or Google), we also receive personal data about you from that service, in accordance with its terms. How we use this data: to allow you to access our service, protect its security, prevent fraud, address issues, communicate with you about the service, and send you newsletters and promotional materials. Legal basis: performance of a contract with you (our Terms of Service), our legitimate interest to maintain and protect our services, and our legitimate interest to market our products. You may unsubscribe at any time by emailing privacy@neurotek.ai.
Participant data. We process any personal data that is provided to us relating to a Participant, including gender, age, country of residence and results of any Assessment. The data relating to the Assessment may be deemed as special categories of data relating to your health, which is subject to special protections under the law. We will only process such data based on the Participant and/or Participant’s legal guardian’s explicit consent. We have no direct engagement with any Participant, and all data collection and obtaining consent will be done by the applicable Customer and/or Permitted User. How we use this data: to provide our services, including conducting Assessments and providing Reports. We also use this data in a pseudonymized manner to improve our services and technology. Legal basis: the explicit consent provided by the Participant and/or the Participant’s legal guardian to the applicable Customer. A Participant may withdraw consent regarding use of the data for improvement of the services by contacting us at privacy@neurotek.ai.
Activity and system data (cookies). We collect data about your device and your activity, as described more fully above in section 2.1, when you use our services.
2.3 Personal data we collect as a processor
Except for personal data we use to improve our services, with respect to any other personal data we process about a Participant, such processing is conducted for the provision of services to our Customers. In that case, we serve as a processor and the Customer serves as a controller. We process that data on behalf of the relevant Customer and according to its instructions. To learn more about our processing activities in this capacity or to exercise your privacy rights regarding them, please contact the applicable Customer directly.
3. Our marketing activities
If you are a Customer and/or Permitted User, we may use personal data we collect for promotional and marketing purposes. We try to limit the marketing material we send to a reasonable and proportionate level.
— We use your contact details to send you informational newsletters and other marketing material about our products and services.
— You can stop the delivery of all marketing emails by following the “unsubscribe” link in any messages we send you, or by contacting us at privacy@neurotek.ai.
— If you are a registered user, you can change your preferences within your account to reflect how you would like us to communicate with you.
— Note that we may need to contact you about administrative or service-related issues as part of the services we provide. This is not marketing communication and you will continue to receive these messages even if you opt out of marketing emails.
4. Sharing the personal data we collect
Customers
With respect to Participant personal data we use to improve our services, the Customer who administered the applicable Assessment serves as a separate independent controller. We will share this data and the results of the applicable Assessments and/or Reports with the applicable Customer. Customers maintain exclusive discretion in determining the appropriate actions concerning the personal data of the applicable Participants.
Service providers
Below are the types of service providers we use and the data shared with each. All service providers have agreed to confidentiality restrictions and have undertaken to use your personal data solely as we direct.
— Cloud computing: providers that offer space on their servers to store our files and programs. All personal data that we collect from you is stored on third-party servers.
— Customer relationship management (CRM): an external tool to keep track of our customers. Shared: your name, company, position, email address, and phone number.
— Email marketing: an independent vendor sends marketing emails on our behalf. Shared: your name, company, position, phone number and email address.
— Bookkeeping services: a third-party service manages our financial transactions and records. Shared: your name, phone number, position, address, and bank account information.
— Analytics providers: assist us with analytics. Shared: data collected automatically through our site, including IP addresses and cookie information.
Change of ownership
If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, your personal data shall continue to be subject to the provisions of this privacy notice.
Law enforcement related disclosure
We may share your personal data with government agencies or other relevant parties: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations.
5. International transfers
Some of our service providers and affiliates are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.
— When we transfer your personal data to Israel, we rely on the decision by the European Commission that those countries are considered to provide an adequate level of data protection.
— Where we transfer your personal data to other countries, we take additional security measures and use the Standard Contractual Clauses approved by the European Commission to give your personal data the same protection it has in the EEA.
Please contact us at privacy@neurotek.ai if you would like further information on the specific mechanism used when transferring your personal data out of the EEA.
6. Security
The security of your personal data is our highest priority. However, it is impossible to guarantee absolute security. The measures we take include:
— Technical measures: secure servers, firewalls, antivirus protections and penetration testing. We encrypt data in transit and at rest using secure SSL protocols.
— Access control: access is limited to authorized personnel with a need to know. Permissions are reviewed regularly and revoked immediately after termination.
— Internal policies: we maintain and regularly review our privacy and information security policies. Personnel: employees sign non-disclosure agreements according to applicable law and customary practice.
— Standards and certifications: we are certified as compliant with ISO 27001 (Information Security Management) and ISO 27799 (Health Informatics Security).
— Database backup: databases are backed up and verified regularly; backups are encrypted and stored within the production environment.
7. Your rights
Depending on which laws apply, you have certain legal rights over your data. To exercise your rights, please contact us at privacy@neurotek.ai. We may ask for reasonable evidence to verify your identity before we can comply with any request.
— Right of access: you may have a right to know what personal data we collect about you (see Article 15 GDPR).
— Right to correct: you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated personal data (Article 16 GDPR).
— Deletion (“right to be forgotten”): if you are in the EU, you may request that we delete your personal data (Article 17 GDPR).
— Right to restrict processing: if you are in the EU, you may ask us to stop processing your personal data (Article 18 GDPR).
— Right to data portability: you may request a copy of the personal data you provided in a structured, commonly-used, machine-readable format (Article 20 GDPR).
— Right to object: you may object to certain processing activities (Article 21 GDPR).
— Withdrawal of consent: you are always free to withdraw consent, without affecting prior processing.
— Right to lodge a complaint: you may submit a complaint to the relevant data protection authority, though we ask that you attempt to resolve any issues with us first.
8. Data retention
We retain your personal data as long as necessary to fulfill each of the purposes described above. Once we’re done with your data, we delete or anonymize it.
When deciding how long to store personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized access, the purposes for which it was collected, and applicable legal requirements. In some circumstances, we may store your personal data even after we’re finished using it if required by law, or to keep accurate records in case there is a prospect of litigation. Contact privacy@neurotek.ai for details about retention periods.
9. Cookies and similar technologies
What are cookies?
A cookie is a small piece of text that is sent to your browser by a website you visit, letting the website know that it’s you (really, your device) that’s visiting. Other technologies act similarly, like web beacons, pixel tags, and device IDs; for simplicity we refer to them all as “cookies”. Websites can place their own cookies (“first-party cookies”) and cookies from other sites (“third-party cookies”). We may place both on our site.
How we use cookies
We will not place any cookies on your browser that are not strictly necessary unless you have first consented to receive them.
— Necessary: allow the site to work correctly. These cookies cannot be disabled.
— Functionality: remember your settings, preferences, and other choices to personalize your experience.
— Security: help us identify and prevent security risks.
— Performance/analytics: collect analytical information about how you use our site to help us improve it.
How to adjust your preferences
Most web browsers are initially configured to accept cookies, but you can change the settings so your browser refuses all cookies or certain types. You are free to delete any existing cookies at any time. Note that some features of the services may not function properly when cookies are disabled or removed.
10. Third-party services
You may have access to third-party services through our services. All use of third-party services is at your own risk and subject to such third party’s terms and privacy policies. We do not take any responsibility for the performance of other services.
11. Children
Participants under the age of eighteen (18) who are using the services may do so only upon the Customer or Permitted User’s receipt of the relevant and required parental consent. If you become aware that an individual under eighteen has enrolled as a Participant without the necessary parental consent, please advise us immediately. Permitted Users and Customers must all be above the age of eighteen (18).
12. Changes to the privacy notice
We may update this privacy notice from time to time to keep it up to date with legal requirements and the way we operate our business. 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.
13. MOXO – privacy summary for kids
We are Neuro-Technology Solutions Ltd. and we think your privacy is important. That’s why we wrote this summary so that you will know what we do with the information we have about you, who we share it with and how we protect it. It’s probably best if you read this together with a responsible grown-up, like a parent. We created the test that you will be taking (the MOXO test) but someone else will actually be giving it to you and managing the results. They will send it to us so that we can store it, analyze it, and help them understand the results. We may use information about your test to help us improve our tests – such information will not include your name or any other detail directly identifying you.
What kind of information do we have about you?
When you take the MOXO test, we get information about you like how good your attention is and other mental skills. Since this information concerns your health, the law says it’s in its own special category and we will only use it if we get permission from your parent or guardian. We also get information your parent or guardian gives us, like your birthday, country, and gender. You can always decide that you don’t want us to have any information about you – but then we may not be able to give you the MOXO test.
Why do we need this information and how do we use it?
We need this information so that the person running the MOXO test can run it properly. We also use it to understand how well the test is working, make it better, and create other tests and services. When we do this, we combine your information with lots of other people’s and remove anything that directly identifies you. If a law says we have to use or share your information in a certain way, we’ll do what the law says.
How do we share your information with others?
We work with other businesses who help us give you the MOXO test and understand how it works. We share your information with them so they can help us. These businesses might not be in the country where you live – when we send them information, we make sure they are just as careful to protect it as we are. If we sell our company, the new owner will treat your information the same way we do. Of course, we’ll also share information with your parents or legal guardians and the person giving you the MOXO test.
How can you decide what we do with your information?
You can ask us to do any of these things, with permission from your parent or guardian first:
— Find out what information we have and ask us to send you (or someone else) a copy.
— Ask us to correct wrong information.
— Ask us to erase any information we have – if we do, we won’t be able to bring it back.
— Sometimes ask us to stop using your information.
— If you’re in the EEA, tell a supervisory authority if you think we did something wrong.
How long do we keep information, and how is it protected?
We only keep information as long as we need it to do the things described in this summary; otherwise we erase it. We checked what security measures are available and what other companies like us do, and we make sure we do at least as good a job. That doesn’t mean everything is 100% safe, but we do our best!
How can you reach us?
If you have any questions, or want us to delete or fix your information, you can email us at privacy@neurotek.ai or call us at +972-8-6466107. Please remember to always speak with your parent or guardian first.