Model Privacy Statement
NeuroReality B.V. takes your privacy very seriously and will process and use data about you (the data subject) only in a secure manner. In this Privacy Statement we explain which data we process and for which purpose we do so. In addition, in this Privacy Statement you can read about your rights regarding our processing of your personal data. We encourage you to read this Privacy Statement carefully.
Who are we?
NeuroReality B.V. located at 1012 JC, Amsterdam at the Warmoesstraat 155, registered in the trade register of the Chamber of Commerce under number 70339937
When does this Privacy Statement apply?
This Privacy Statement applies to all personal data that NeuroReality B.V. is processing from anyone who uses the Koji’s Quest app, hereafter App.
What are personal data?
Personal data are all data that can be traced to you as an individual. Just think of your name, phone number, address or e-mail address. But data such as your IP address is also personal data.
What do we use your personal data for?
We process your personal data for the following purposes:
• providing access to our App
• using the functionalities of our App
• entering into and agreements via our App
• conducting conversations via the App
• contacting you, if requested
• gaining insight into the use of our App
• gathering progress you made in the App in order to present you with your progress
• improving and evaluating our App
• processing applications, a separate privacy statement applies to applications, which can be found with the application form
Which data do we process?
We use the following personal data for the purposes stated in this privacy statement:
· Username
· Gender
· Age
· Educational level
· E-mail address
· IP address
· Mood
· Amount of sleep had
How do we collect personal data?
The personal data of the visitors are obtained in the following ways:
· Through the use of the App and the cookies placed thereon;
· By providing personal data by the data subject (user) him/herself.
· By playing the App, personal progress information is generated
Do we provide data to third parties?
We do not provide your data to third parties without your prior consent, unless this is necessary in the context of the execution of an agreement. Or we must do so on the basis of the law.
We can provide your data to the following companies that process your information (processor):
· Amazon Web Services (AWS): Cloud servers whose privacy policy can be found at: https://aws.amazon.com/privacy/
· MailChimp: A party that provide mailings for us whose privacy policy can be found at: https://mailchimp.com/legal/privacy/
How is your data secured?
We take the protection of the personal data of our users of the App seriously and therefore take appropriate organizational and technical measures to prevent misuse, loss, unauthorized access, unwanted disclosure, unauthorized modification or otherwise unlawful processing.
Our employees who have access to your personal data are bound by a confidentiality clause and only have access to this personal information if necessary for the performance of their duties and / or support of the App.
How long do we retain personal data?
We will retain your personal data for the period necessary to fulfil the purposes outlined in this Statement, unless a longer retention period is required or permitted by applicable law.
Rights regarding personal data
You have certain rights with regard to your personal data. In accordance with the law you may have the right to request a copy of your personal data and further, where reasonably possible, have access to your personal data. You also may have the right to rectify and erase your personal data or to restrict or object to the use of your personal data. Furthermore you may have the right of data portability.
Right to information
A core principle of the GDPR is that data subjects should be entitled to a minimum set of information concerning the purposes for which their personal data will be processed to ensure the fair processing of personal data.
Right of access
You have the right to request access from us at any time to the data that we have processed about you. More specific you have the right to get:
• confirmation of whether we are processing your personal data;
• information about the purposes of the processing;
• information about the categories of data being processed;
• information about the categories of recipients with whom the data may have been shared;
• a copy of those data (in an intelligible format) and information as to the source of those data;
• an explanation of the logic involved in any automated processing that have a significant effect on data subjects.
Right of rectification
You have the right to rectification of inaccurate personal data.
Right to erasure (the “right to be forgotten”)
You have the right to erasure of personal data (the “right to be forgotten”) if:
• the data are no longer needed for their original purpose (and no new lawful purpose exists);
• the legal basis for the processing is your consent, and you withdraw that consent, and no other lawful ground exists;
• If you exercise the right to object, and the we have no overriding grounds for continuing the processing;
• the data have been processed unlawfully; or
• erasure is necessary for compliance with EU law or the national law of the relevant Member State.
Right to object processing
You have the right to object to the processing of your data if you do not agree with the way we process your personal data.
Right to data portability
You have the right to receive information that you have given to us in the context of the agreement (s) you have concluded with us in a machine-readable format, so that you can store this information in a database of you or of a other party.
Right to Restriction
You have the right to request the restriction of the processing of your data. This means that we may keep your data but not use it. This right arises in a number of cases. If you believe this is the case, you can contact us.
Right to not be evaluated on the basis of automated processing
You have the right not to be subjected to a decision based solely on automated processing which significantly affect you (including profiling). Such processing is permitted where:
• it is necessary for entering into or performing a contract with you provided that appropriate safeguards are in place;
• it is authorized by law; or
• the data subject has explicitly consented and appropriate safeguards are in place.
Right to file a complaint
You have the right to file a complaint about the way in which we handle your data.
The request to exercise one or more of the above rights can be submitted in writing to the address stated at the end of this statement.
When we receive a request, depending on the nature of the request, we will first weigh up the interests and assess whether we can and must comply with the request. Then we will send an appropriate response.
If you have not received a timely reply to your request or if the request has been rejected, you can lodge a complaint. Send your complaint to: privacy@neuro-reality.com or with the supervisory authority.
Can this Privacy Statement be changed? The terms of this Privacy Policy will govern the use of the Properties and any information collected therein. NeuroReality B.V. reserves the right to change this policy at any time, so please re-visit this
page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Site or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Site or sent to you via e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Platform on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice
This privacy statement was last modified on: 11/11/2020
Where can you go to with questions and complaints?
If you have any questions about this Privacy Statement and the way we process your data, you can contact us via the contact information at the bottom of the document. Also if you have a complaint about the way we process your data, you can contact us. You are also free to contact the competent national supervisory authority. In the Netherlands this is the Autoriteit Persoonsgegevens.
Privacy contact:
privacy@neuro-reality.com