PRIVACY POLICY
This Privacy Policy explains how information about you is collected, used, and disclosed by Neurotechnology Pty Ltd and any parent or subsidiary (collectively, “Neurotechnology,” “our”, “us” or “we”) when you access or use Neurotechnology Pty Ltd websites, mobile applications, and other products and services (collectively, the “Services”) or otherwise interact with us. This policy applies to Neurotechnology Pty Ltd brands, websites, applications, and other technologies (we collectively refer to these as “Services”).
Our Privacy Pledge
Our commitment is to put users first. We strive to be transparent about how we collect and use information from our users, to keep the information we collect secure, and to provide users meaningful choices. Since our founding in 2018, Neurotechnology Pty Ltd has intentionally avoided collecting data that identifies specific individuals (such as name, email address, physical address, GPS or phone number) to the extent possible. Neurotechnology Pty Ltd has appointed a Data Protection Officer to ensure Neurotechnology Pty Ltd maintains safe and consistent practices regarding your data and privacy.
Collection of Information
We collect the following types of information when you interact with our Services:
Device Identifiers
When you interact with our Services, we do not require you to provide information that identifies you personally. Instead, we collect and identify your device primarily using your mobile device advertising identifier, e.g. Apple’s iOS Identifier for Advertising (IDFA) or Google’s Android Advertising ID, as well as other identifiers.
User Names.
To help protect your privacy, please do not choose a username which could be used to personally identify you, e.g. “JimSmith” or “Jsmith”.
Other Information You Provide to Us.
We collect the information that you provide to us, for example when you communicate with others or post, upload or store content, contact our Technical Support team, or provide billing information.
Log Information.
We automatically collect information about your use of our Services and your device, including your IP Address, device model, browser version, operating system type, operating system version, mobile network information, device settings, and software data.
Location Information.
We derive information about your general location (city, country) from your IP Address. Neurotechnology Pty Ltd does not collect precise location data, such as GPS coordinates, that could be used to pinpoint your physical location.
Information from Cookies and Other Technologies.
We collect information using web beacons, cookies, and similar technologies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, count visits, and understand how users interact with ads. Web beacons are electronic images that may be used in our Services and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see “Your Choices” below.
Information from Others.
We collect information about you when we receive it from other users, third parties, and affiliates. For example, when you connect your account to third-party services or sign in using a third-party partner (like Steam, Google Play Game Services, iOS Game Center or Facebook), we collect information in accordance with the privacy policies and authorisation procedures determined by those services.
Advertising and Analytics Services Provided by Others.
We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Neurotechnology Pty Ltd and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity.For more information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalisation” on Android) that allows you to opt out of having certain information collected through apps used for interest-based advertising purposes.
Advertising and Analytics Services Provided by Others
We use the information we collect to deliver, personalise, and improve our Services. We also use the information we collect to:
- Personalise the Services and provide advertisements, content, or features that are targeted toward your interests;
- Save and associate your activity across our Services and your different devices as well as associate any accounts you may use across Neurotechnology Pty Ltd Services together. We may associate activity and accounts under a single user ID;
- Carry out or support promotions;
- Create analytics and reports for external parties, including partners, publishers, advertisers, apps, third-parties and the public regarding the use of and trends within our Services and ads, including showing trends to partners regarding general preferences, the effectiveness of ads and information on user experiences; and
- Detect and defend against fraudulent, abusive, or unlawful activity.
Sharing of Information
We share the information we collect within the Neurotechnology Pty Ltd family of brands. We do NOT sell, license or share information that individually identifies our users with companies, organisations or individuals outside of Neurotechnology Pty Ltd unless one of the following circumstances applies:
With Our Brands.
Neurotechnology Pty Ltd shares information within its own brands.
With Your Consent.
We will share information with companies, organisations or individuals outside of Neurotechnology Pty Ltd when we have your consent to do so.
For Legal and Other Purposes.
We may access, preserve, and disclose information to investigate, prevent, or take action in connection with: (i) legal process and legal requests; (ii) enforcement of our Terms of Service; (iii) claims that any content violates the rights of third parties; (iv) protecting the rights, property or personal safety of Neurotechnology Pty Ltd, its users, or the public; (v) establishing or exercising our legal rights or defending against legal claims; or (vi) as otherwise required by law.
New Ownership.
If the ownership or control of all or part of Neurotechnology Pty Ltd or specific Services changes as a result of a merger, acquisition or sale of assets, we may transfer your information to the new owner.
Your Choices
Accounts.
In most cases, you can easily delete your data at any time by deleting the app and/or resetting your Advertiser ID. We can no longer associate any stored data with you. If you have linked a social account (e.g. FaceBook, GPGS or GameCenter), then you can unlink the app with those social providers to disassociate yourself with any stored data. If you do this, your unique username and game play may no longer be retrievable. If you have any further questions regarding remove of data, please contact [email protected].
Cookies.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies; however, the Services may not function properly if you do so.
Notifications.
You have the ability to turn application notifications on and off by adjusting the settings of your mobile device. If you wish to allow or discontinue receiving Push Notifications or Local Notification, please consult the settings on your mobile device.
Information Security
Neurotechnology Pty Ltd has adopted commercially reasonable technical, administrative and physical safeguards in place to help protect against unauthorised access, use or disclosure of customer information we collect or store.
Data Retention
We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
Protecting Children’s Privacy
Our Services are not intended for use by children. We do not knowingly collect, use, or share information from children under age 16. If you believe that your child may have provided us with personal information, please contact us at [email protected].
Data Transfers
Neurotechnology Pty Ltd is based in Australia and we process and store information in the Oceanic Region. As such, we may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.
Residents of the European Economic Area
Legal Basis for Processing
If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:
- We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).
- We have a legitimate interest in processing your personal data. For example, we may process your personal data to keep track of your game play.
- We have your consent to do so. For example, we may seek your consent to show you interest-based ads.
Data Subject Requests.
If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to withdraw a consent you previously provided, or to object to or request that we restrict certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.
Questions or Complaints.
If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see:
Changes to the Privacy Policy
Neurotechnology Pty Ltd may change this Privacy Policy at any time. If we make a change, we will notify you by revising the “Effective Date” date above and, in some cases, we may provide you with more prominent notice. We encourage you to review this Privacy Policy frequently to stay informed about our information practices and your privacy choices.
Contact Information
If you have questions, suggestions, or wish to make a complaint, please complete a feedback form or you can contact us at:
Neurotechnology Pty Ltd
'6 Edgecliff Mews'
193-201 New South Head Road
Edgecliff
NSW Australia 2027
© 2023 Neurotechnology Pty Ltd
Acknowledgment of Country
In the spirit of reconciliation Neurotechnology acknowledges the Traditional Custodians of country throughout Australia and their connections to land, sea and community. We pay our respect to their Elders past and present and extend that respect to all Aboriginal and Torres Strait Islander peoples today.
