Welcome to Neuphony’s Privacy Policy

The following Terms of Use describes how, Neuphony (owned by and affiliates M/s. Pankhtech OU, “we, “us” or “our”) collect, store, use, process, retain, transfer, disclose and protect your personal information that we obtain through www.neuphony.com (“Website”) and our mobile applications neuphony.app (“Application/Platform”).

To provide you with our uninterrupted use of the services, we may collect and, in some circumstances, disclose information about you with your permission. To ensure better protection of your privacy, we provide this notice explaining our information collection and disclosure policies, and the choices you make about the way your information is collected and used.


This Privacy Policy shall be in compliance with the General Data Protection Regulation (GDPR) in effect from May 25, 2018, and any and all provisions that may read to the contrary shall be deemed to be void and unenforceable as of that date. If you do not agree with the terms and conditions of our Privacy Policy, including in relation to the manner of collection or use of your information, please do not use or access the Website. If you have any questions or concerns regarding this Privacy Policy, you should contact our Customer Care.


This Privacy Policy includes the following matters:

1. INTRODUCTION

2. REGISTRATION

3. COLLECTION OF YOUR INFORMATION

4. ELIGIBILITY

5. USING YOUR INFORMATION

6. ANALYTICS AND ADVERTISING

7. YOUR RIGHTS

8. CONFIDENTIALITY

9. INFORMATION SHARING WITH THIRD PARTIES

10. DISCLOSURE OF YOUR INFORMATION

11. CONTROL OF YOUR PASSWORD

12. SECURITY OF YOUR INFORMATION

13. PERMISSIONS SOUGHT FROM THE DEVICES

14. SEVERABILITY

15. AMENDMENT

16. CONSENT WITHDRAWAL, DATA DOWNLOAD & DATA REMOVAL REQUESTS

17. HOW TO CONTACT US

 

1. INTRODUCTION

Neuphony believes in unlimited potential of the human mind and strives towards unlocking it to bring out the best in them. Neurofeedback has been scientifically proven to be a powerful tool to improve the overall health of your brain including improving memory, sleep quality and reducing stress and anxiety. Neuphony brings you the benefits of the neurofeedback at the comfort of your home with the help of our headband and a mobile Application. The headband measures the electrical activities of your brain and the Application based on the sensor data recommends you meditation techniques to achieve your desired state. Over sessions it trains your brain on how to achieve the desired state itself.

 

2. REGISTRATION

Registration is mandatory for all users of our Platform. Further, linking of social media accounts is limited to Google account and Apple account. Users are deemed to be registered after an email verification is completed on their registered email Id.

 

3. COLLECTION OF YOUR INFORMATION

The Services is committed to respecting online privacy. Only the following information is collected:
a)  Self- provided information.

Our Services collects and stores the following information that the users choose to provide:

User Information, such as name, gender, age, and email ID that you provide.

b) Information collected by our Services.

  • Certain information may be collected by navigating from page to page, or via third party tracking while using our Services. The following information is collected:
  • User interaction with our Services, such as the pages visited, searches, and the dates and times of such visits.
  • EEG Data collected by neuphony headband, which is used to track brain waves and recommend the right meditation style for each user.
  • Information about the device and software used to access our Services, including IP address, web browser type, operating system version, and device identifiers.

 

4. ELIGIBILITY

  • You represent and warrant that you are competent and eligible to enter into legally binding agreements and of age and that you have the requisite authority to bind themselves to these Terms of Use following the Law. However, if you are minor using this platform, you may do so with the consent of your legal guardian. All Acts of minor shall be deemed to be considered as the acts undertaken under the supervision of their legal guardian.
  • You further represent that you will comply with these Terms of Use and all applicable local, state, national and international laws, rules and regulations.
  • You shall not use the Platform if you are not competent to contract or are disqualified from doing so by any other applicable law, rule or regulation currently in force.

 

5. USING YOUR INFORMATION

  • To provide and help you with services on your request.
  • For maintaining an internal record.
  • For enhancing the Services provided.
  • For maintaining record under the legal and statutory provisions.For more details about the nature of such communications, please refer to our Terms of Service.Further, your data may be collected and stored by us for internal record. We use your tracking information such as IP addresses, and or Device ID to help identify you and to gather broad demographic information and make further services available to you. We will not sell, license or trade your personal information. We will not share your personal information with others unless they are acting under our instructions or we are required to do so by law. Information collected via our server logs includes users’ IP addresses and the pages visited; this will be used to manage the web system and troubleshoot problems. We also use third-party analytics, tracking, optimization and targeting tools to understand how users engage with our Services so that we can improve it and cater personalized content/ads according to their preferences.

6. ANALYTICS AND ADVERTISEMENT

Our Services may include advertisements, hyperlinks to other websites or resources. We have no control over any other website or resources or contents available on these other websites, which are provided by companies or persons other than us. You acknowledge and agree that we are not responsible for the availability of any such external sites or resources, and do not endorse any advertising, services/services or other materials on or available from such website or resources. You acknowledge and agree that We are not liable for any loss or damage which may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, services or other materials on, or available from, such websites. These external third party websites and resource providers may have their privacy policies governing the collection, storage, retention and disclosure of your personal information that you may be subject to.

 

7. YOUR RIGHTS

Unless subject to an exemption, you have the following rights concerning your data:

  • The right to request a copy of your data which we hold about you;
  • The right to request for any correction to any personal data if it is found to be inaccurate or out of date;
  • The right to withdraw your consent to the processing at any time;
  • The right to object to the processing of personal data;
  • The right to complain about a supervisory authority.
  • The right to obtain information as to whether personal data are transferred to a third country or an international organization.

Where you hold an account with any of our services, you are entitled to a copy of all personal data
which we hold concerning you. You are also entitled to request that we restrict how we use your
data in your account when you log in.

 

8. CONFIDENTIALITY

You further acknowledge that our Services may contain information which is designated confidential by us and that you shall not disclose such information without our prior written consent. Your information is regarded as confidential and therefore will not be divulged to any third party, unless if legally required to do so to the appropriate authorities. We will not sell, share, or rent your personal information to any third party or use your e-mail address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed services, and you retain sole discretion to seek for discontinuation of such communications at any point of time.

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. If the same is not identified to you, you have the right to request our Services to elucidate the purpose of collection of said personal information, pending the fulfilment of which you shall not be mandated to disclose any information whatsoever. We will collect and use your personal information solely to fulfil those purposes specified by us, within the scope of the consent of the individual concerned or as required by law. We will only retain personal information as long as necessary for the fulfilment of those purposes. We will collect personal information by lawful and fair means and with the knowledge and consent of the individual concerned. Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.Our Platform collects and processes EEG data from its users. This data is not sold to any third part or anyone unrelated to our Platform. We take the protection of this data very seriously, thus the data is highly confidential.

 

9. INFORMATION SHARING WITH THIRD PARTIES

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are on our Services or other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. To the extent that we use third party advertisers, they adhere to their privacy policies. Since we do not control the privacy policies of the third parties, you are subject to ask questions before you disclose your personal information to others.

 

10. DISCLOSURE OF YOUR INFORMATION

We may host surveys for survey creators for our Services who are the owners and users of your survey responses. We do not own or sell your responses. Anything you expressly disclose in your responses will be disclosed to survey creators. Please contact the survey creator directly to better understand how they might share your survey responses.

Information collected will not be considered as sensitive if it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005, any rules made thereunder or any other law for the time being in force.

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting and foregoing), we may be forced to disclose information to the government, law enforcement agencies or third parties. Therefore, although we use industry-standard practices to protect your privacy, we do not promise, and you should not expect, that your personally identifiable information or private
communications would always remain private. We do however assure you that any disclosure of your personally identifiable information shall be personally intimated to you through an email sent to your provided email address.

As a matter of policy, we do not sell or rent any personally identifiable information about you to
any third party. However, the following describes some of the ways that your personally
identifiable information may be disclosed:

a. External Service Providers: There may be several services offered by external service providers that help you use our Website. If you choose to use these optional services, and in the course of doing so, disclose information to the external service providers, and/or permit them to collect information about you, then their use of your information is governed by their privacy policy.

b. Law and Order: We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as intellectual property rights, fraud and other rights. We can (and you authorize us to) disclose any information about you to law enforcement where the FIR is filed against the user and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.

 

11. CONTROL OF YOUR PASSWORD

You are entirely responsible for maintaining the confidentiality of your password. You must protect it against unauthorized access of your account and information by choosing your password carefully and keeping your password and computer secure by signing out after using our services. You agree not to use the account, username, email address or password of another Member at any time or to disclose your password to any third party. You are responsible for all actions taken with your login information and password, including fees. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. You agree to notify us immediately if you suspect any consistent unauthorized use of your account or access to your password even after changing it.

 

12. SECURITY OF YOUR INFORMATION

We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by members inside and outside of our Services. We follow generally accepted industry standards to protect the Personal Information submitted to us and information that we have accessed.However, as effective as encryption technology is, no security system is impenetrable. Our Services cannot guarantee the security of our database, nor can we guarantee that information you provide will not be intercepted while being transmitted to other services over the Internet.

 

13. PERMISSION SOUGHT FROM THE DEVICES

Our Platform can be accessed by both Android and iOS softwares. Further, the Platform accesses the Bluetooth connection of the device. The Bluetooth connection is used for the headband being connected to the Platform.

 

14.  SEVERABILITY

Each paragraph of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the agreement. The decision or declaration that one or more of the paragraphs are null and void shall not affect the remaining paragraphs of this privacy policy.

 

15. AMENDMENT

Our Privacy Policy may change from time to time. The most current version of the policy will govern our use of your information and will always be at our Services. Any amendments to this Policy shall be deemed as accepted by the User on their continued use of our Services.

 

16. CONSENT WITHDRAWAL, DATA DOWNLOAD & DATA REMOVAL REQUESTS

To withdraw your consent, or to request the download or delete your data with us for any or all our services at any time, please email to support@neuphony.com .

 

17. CONTACT US

If you have any questions or concerns regarding this privacy policy, you should contact us by sending an e-mail to please email to support@neuphony.com