NeuroSonica Privacy Policy

This policy applies from 16th June 2019

 

Introduction

We at NeuroSonica Pty Ltd. (“NeuroSonica,” “us,” "our" or “we”) are committed to respecting and securing our customer data. Like you, we object to spam or the abuse of our private email addresses or other personal information. Therefore, we treat you as we would ourselves and process your personal data (data about identified or identifiable individuals), with all due care and in accordance with applicable data protection laws. 

Many of you will have come to this page to check our Privacy Policy while in the process of downloading or purchasing the Sleep Solutions with DeStress mobile app, or visited this page by clicking Privacy Policy on the installed app itself.

For your convenience we will preview privacy information specifically relevant to the App before proceeding to our full Privacy Policy.

Below you will find:

1          Details regarding the use and protection of data required by the Sleep Solutions App

2          Our full Privacy Policy

 

1  Data Required during the Download of the Sleep Solutions with DeStress app, or during any In-App Purchase on that app.

The platform from which you downloaded the app (Apple App Store) may already hold your relevant user account details, and information about the device onto which you have installed the app. Please check the Privacy Policy of those platforms for details about how your personal information is used and protected.

With your permission, we may use in-app communications or push notifications to let you know of App version updates, or the release of other products.

 

2  Our Full Privacy Policy

This Policy is compliant with GDPR requirements and covers the following in a clear and transparent manner:

• What data do we collect? The specific kinds of personal data we may collect and process about you as a customer and through your use of our apps, website, online services and mobile applications.

• How do we collect, use and store your data? The ways and means in which we collect and process that personal data according to  applicable data protection laws plus the sources from which this personal data is obtained, what we do with it, how long it is retained and how it is stored

• Privacy policies of other websites connected to us and those persons and/or entities to whom we may disclose or transfer your personal data

• Your data protection rights and the various ways in which we comply with data protection laws/ rules and deal with your data protection rights.

• All about our cookies. What are cookies, how we use them, what types do we use and how are they managed?

• Our marketing

• Changes to our privacy policy

• How to contact us and appropriate authorities

Please carefully read through the following information to understand the practices we employ regarding your personal information and our collection, use and disclosure of this personal information.

Who is the Data Controller?

In legal terms, we, NeuroSonica Pty Ltd (referred to as “we”, “us”, “our” or “NeuroSonica” in this policy) are the data controller, as we determine the means and/or purposes of  the processing of personal data for the purposes of privacy and data protection laws, principles and regulations which may apply in your country.

What personal data we may collect from you

Your personal data consists of any information about you which allows us to identify you as an individual to fulfil our legal duties, provision of services and customer relations. NeuroSonica may collect and process the following data from you (either directly or indirectly, through our third party partners or providers) in a number of ways.

Your personal data may include the following:

• Personal information such as; your name, telephone, e-mail address, information regarding your use of our website including details of products or services you have purchased and information collected by tracking technologies that may identify you as an individual or allow online or offline contact with you as an individual.
• Any communications with us via emails, letters, chat services, phone calls and through the use of social media.
• Device Information including device type, operating system version, and system performance information.
• NeuroSonica does not collect or process your debit or credit card (“Payment Card”). Our payment processor www.c54e4e5635912ef26f54b51cd9a13fa6-gdprlock collects Payment Card information regarding purchases made through the Website.  Our payment processor may provide us with certain limited information relating to you, such as a unique token to enable you to make additional purchases using this stored information, your card’s type, billing address, expiration date, and the last four digits of your card number.

Our Blogs or Forums

In order to post comments to the NeuroSonica Blog on our site you need to register as a member of NeuroSonica, which will require providing a username and a valid email address.  Your email address is protected on our site by Locked Administrator Login, Password encryption, and our server level Firewall protection.

If you register as a member of a NeuroSonica Forum your personal information is protected on our site by Locked Administrator Login, Password encryption, and our server level Firewall protection.

Why and how we may use your personal data

NeuroSonica processes your personal data to allow us to run, maintain and develop our business, to fulfil the provision or delivery of our goods or services to you the customer, and to comply with legal requirements.

Therefore your personal data may be used:

• To facilitate our customer service communications we may use your personal data for managing your customer relationship with us, fulfilling contracts, and for improving our services to you so as to enhance your user experience with us.
• To allow us to conduct promotional and information campaigns related to our services
• To provide services or products you may request or may have signed up to receive
• For payment information necessary for accounting, audit and billing purposes or for the detection or prevention of fraudulent or illegal activities such as IP or copyright vilolations etc.
• For enabling legal and/or administrative purposes. These may include your data being used for various types of services tracking, research and analysis including systems testing, customer and market surveys, statistical analysis, maintenance and development, and for dealing  with any potential claims or disputes.
• With your prior consent, we may also at times perform data profiling based on data collected from you for the purposes of marketing and statistical analysis.
• In order to ensure the facilitation of any security, administrative and/or crime prevention/detection requirements we may forward your personal data and information to relevant enforcement bodies and/or government authorities as needed to comply with any legal requests for the provision of such data.
• To facilitate the provision of any customised or other services. Your data may be used to provide you with information we consider to be of personal interest to you, prior to, during, and after your interactions with us including such things as special or time limited offers, discounts, bundles etc.

Only those aged 18 years or older can provide their consent for us to use their personal data. Children below this age must have the consent and knowledge of their parents or legal guardians in order to provide us with such information.

How long we retain your personal data and what criteria are used

NeuroSonica do not store or retain your personal data for longer than is required either to fulfil identified purposes or as is required by law, whichever is the longer timeframe. We establish retention criteria depending on the nature and amount of the personal data and the purposes for its processing. Typically, we store it for as long as the user is using our services or for as long as it’s needed for other purposes or contingencies such as meeting any legal obligations, or for dealing with any complaints or queries. Our policy is to erase personal data when it is no longer required for any other such purposes, or when the user formally requests us to erase their personal data and this is not in breach of any applicable laws.

Where your personal data is stored and how it is secured

NeuroSonica implements and maintains strict technical and organizational security procedures in the storage and disclosure of your personal data in order protect it against unauthorized access, alteration, disclosure, accidental damage, loss or destruction. All personal information you provide to us is stored on our secure servers located in Australia.

On our site your personal information is protected by Locked Administrator Login, Password encryption, and our server level Firewall protection.

Who do we share your personal data with?

Your personal information may also be disclosed by us to third parties as follows                                                

• We may share personal data with law enforcement bodies and regulators for compliance with legal requirements and/or Government authorities, legal and other professional advisers, law courts and law enforcement bodies in any countries we operate if we consider their access to and use of the personal data is necessary for meeting any applicable law and/or court order; to detect, prevent or otherwise address security, fraud, or technical issues, and/or  to protect the interests, properties or safety of NeuroSonica, our users or the public, in accordance with the law. It is our policy to  notify users about any such disclosure,in a reasonable time frame  as far as is possible. 

• Personal data may also be shared with other companies, agents or contractors offering and/or providing services or goods including marketing, support ticket providers, legal services, administration and customer services, information technology providers, credit card or other payment options that complement our own services and goods for the purpose of enhancing user experiences.

In the event of a merger, acquisition or asset sale, we may also likewise transfer personal data to the involved third party whilst maintaining its confidentiality. 

• Personal data may be shared with credit and debit card companies involved in facilitating your payments to NeuroSonica, as well as for screening against fraud, if they require information regarding your payment methods in order to  process payment transactions or  ensure their security. Such entities may include third party payment gateway providers such as  www.c54e4e5635912ef26f54b51cd9a13fa6-gdprlock or www.apple.com. We suggest you  read and familiarise yourself with the privacy policies of any such third parties before entering your personal details.

• In the event that you access third party social media services through our website(s) or app , we may receive personal data you choose to share with us through such social media services, providing this complies with their privacy settings. This data may be used  as a means of  personalising and improving your use of our app or website(s). Further, as we may also use social media plugins such as ‘share’ or ‘like us’ buttons on our app or website(s) your information will be shared with your social media provider and possibly with others in your network. We suggest you refer to their privacy policies of any such third-party social media providers to find out more about these practices.

• Other recipients of your personal data may include our third party ancillary partners offering products and services on or through our website. As we are not responsible for third party use of your personal data we suggest you read and familiarise yourself with their privacy policies before entering your personal details.

• We may at times also share personal data with third parties for other reasons than the ones mentioned above, if we obtain a user’s explicit consent to do so. The user likewise has the right to withdraw this consent at any time. 

Where you have been provided with a password enabling your access to certain parts of the products or service, it is your responsibility to keep this password confidential. We request you do not share a password with anyone else.

Transferring International Data Beyond the EEA and GDPR compliance

Data privacy is important to us across all countries as NeuroSonica operates its business in multiple jurisdictions throughout the world.  These may include those beyond the European Union(EU) or European Economic Area (EEA) which may therefore be exempt from compliance with the EU General Data Protection Regulation (GDPR). While such countries outside the EEA vary greatly in the strength of their data protection laws, we nonetheless require that all services providers process your personal information securely and in accordance with EU and other applicable international laws on privacy and data protection.

Tracking & Cookies Data

NeuroSonica uses ‘cookies’ and may use similar tracking technologies such as beacons, tags, and scripts to help track, analyse and improve the activity on our service by holding certain information including demographic or internet-based data and internet browsing behaviour.

A cookie is a small text file stored on your computer which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

Cookies therefore contain information in order to help the website identify and track the visitor. They are harmless to your computer, do not contain viruses, consist purely of text, and occupy virtually no space on your hard drive.

While you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent, by not accepting cookies, you may experience some problems using our site or online services.

Some of our advertisers may use cookies on your computer in which case their use of cookies is subject to their own privacy policies and not to this Policy. You are encouraged to read carefully the advertisers’ policies.

Two types of cookies are used: "Session Cookies", and cookies that are saved permanently on your computer.

The first type of cookie commonly used is "Session Cookies". During the time you visit the website, our web server assigns your browser a unique identifier string so as not to confuse you with other visitors.  A "Session Cookie" is never stored permanently on your computer and disappears when you close your browser. To use our website without troubles we recommend that you have cookies enabled.

The second type of cookie saves a file permanently on your computer. This type of cookie is used to track how visitors move around on the website. This is only used to offer visitors better services and support. The text files can be deleted. On this website we use this type of cookie to keep track of your shopping cart and to keep statistics of our visitors. The information stored on your computer is only a unique number, without any connection to personal information.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

To opt out of cookies, you can alter the settings on your internet browser to accept or reject a website from using cookies. This may affect functionality of the website.

Some third parties may use cookies and other technologies. We recommend that you read their privacy policies or policies relating to the use of cookies and technology.

When you browse our site we automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.

We may also collect data regarding device IDs or identifiers, connection information, device software, statistics of page views, ad data, referral URLs and IP data; to determine your general geographic location, so that we can provide location-specific content to you; to assist in responding to complaints and queries; to investigate any possible breach of our terms or conditions including fraud or illegal activities with the use of your personal data; and with your permission, we may send you emails about our store, new products, and other updates.

If we do ask for your personal information for a secondary purpose such as marketing and you are an individual in the European Economic Area (EEA), we will ask you directly for your express consent.

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you for the continued collection, use or disclosure of your information, at any time, by contacting us or by using the unsubscribe link within any of our emails.

If you are outside of the European Economic Area (EEA), you may withdraw your consent for us to contact you for the continued collection, use or disclosure of your information, at any time, by contacting us or by using the unsubscribe link within any of our emails.

We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of websites. This software does not enable us to capture any of your data.

Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy.          

Your Data Protection Rights

Under certain circumstances, by law you have the right to:

1. Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
2. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
3. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
4. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see e. below).
5. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
6. Request not to be the subject of any automated decision-making by us using your personal information or profiling of you.
7. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
8. Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
9. Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes to which you originally agreed, unless we have another proper and legitimate basis for doing so.          

Accessing, editing or deleting your information

At your request, we will provide you with information regarding whether we process or hold, on behalf of a third party, any of your personal information. If you wish to request this information, please This email address is being protected from spambots. You need JavaScript enabled to view it..

At any time, you may access your personal information for modification or updating via an online account, or by emailing This email address is being protected from spambots. You need JavaScript enabled to view it..

Should you wish to delete your personal data on our files please email us at This email address is being protected from spambots. You need JavaScript enabled to view it..

Our response to any such requests will be made in a reasonable timeframe.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly completely unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Deleting your posts on our Blog or Forums

You can request that we delete one or all posts you have made to our company Blog, or to any NeuroSonica discussion Forum of which you are a member. Simply detail your request in an email to This email address is being protected from spambots. You need JavaScript enabled to view it..

Changes to our Privacy Policy

Our privacy policy may change from time to time. Any changes will be communicated to you by way of an e-mail or a notice on our website. 

If you are using the Sleep Solutions App we recommend you click on Version Updates and Other News from time to time, as we will also announce any changes to our Privacy Policy on that page.