Neuromotion Inc. Privacy Policy

The Neuromotion website, application and proprietary emotional regulation software platform that operates in connection with the associated heartrate monitor (the “Service”) is owned and operated by Neuromotion Inc. (“Neuromotion”) and made available to our registered users.

This Privacy Policy describes:

Why we collect personal information

  • What personal information we collect and when it is collected
  • Our lawful basis for collecting and using personal information
  • How your information is used and protected
  • When and with whom your information is shared
  • Your choices regarding your personal information

We encourage you to read this Privacy Policy and our Terms of Use carefully. Capitalized terms used but not defined in this Privacy Policy have the meaning given them in the Terms of Use. We will post notices of all changes that materially affect the way in which your personally identifiable information may be used or shared in updates to our Privacy Policy.

This policy does not apply to those third-party advertising systems, networks or websites that Neuromotion has a relationship with or of other companies or individuals that Neuromotion does not own, employ, manage or control.

Information We Collect

We comply with the Children’s Online Privacy and Protection Act (“COPPA”), which among other things requires that we obtain verifiable parental consent before we collect personally identifiable information online from children who are under 13. Therefore, we only collect personal information through the Services from a child under 13 where that student’s parent or authorized legal guardian has agreed that their child may use the specifically tailored, age-appropriate games and other apps available through the Service, through which we may from time to time collect game usage information such as IP address and heart rate, and user responses to and feedback based on tailored questions about the user’s game experience. If you are a student under 13, please do not send any personal information about yourself to us if your parent or guardian has not expressly consented, and please do not send any personal information other than what we request from you in connection with the Services. If we learn a student under 13 has provided us personal information beyond what we request from him or her, we will delete that information as quickly as possible.

The information we learn from users helps us not only provide the Service but also to personalize and continually improve each user’s experience with the Service. Here are the types of information we gather:

Information You Give Us

When your child plays games on our app, we collect your child’s heart rate, game statistics, and IP address. This information is required for us to deliver the Services to you effectively. If you choose not to permit us to access this information, you may not be able to use the Services effectively. We will not collect from your children, or ask your child to disclose any information that is not reasonably necessary to participate in the Service.

Like many other websites, we also collect information through cookies and other automated means. Information of this sort includes:

  • Technical information about your browser and mobile device: This information is used in the aggregate to help us optimize the Service for common browsers and devices.
  • Usage information, such as the customized sonar and radar settings, features and emails from Neuromotion that you interact with. We collect and use this behavioral information and may use it in anonymized and aggregate forms to generate statistics about users and how the Services are being used and to facilitate targeted communications and advertisements but the information is not shared in any form that could be used to identify you or your child personally. Please see “How we use and share the information we collect,” below, for further information and choices about sharing information with third parties.
  • IP address and log file information, web beacons, cookies, tokens and device identifiers: These are alphanumeric identifiers that help us to distinguish between unique browsers and devices in order to avoid showing you the same information twice, keep you logged into Neuromotion, prevent duplicate actions, prevent duplicate coupon redemptions and improve your experience. The information we collect from cookies may include your IP address, browser and device characteristics, referring URLs, and a record of your interactions with our Service.

By using the Service, you are consenting to such use of cookies. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie.

We will respect your choices relating to on-line tracking, whether you choose to reject individual cookies or set your web browser to reject cookies and other tracking technology. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Service or certain areas or features of the Service.

Crashes and error reports: If you encounter a crash or error while using our Service, we may generate a crash report that includes technical, usage and, if you are logged in, your account information so that we can diagnose and potentially prevent the problem in the future.

Information Collected from other Sources. We may also periodically obtain both personal and non-personal information about you from our service providers, contractors and other third parties you have authorized to share such information with us.

Lawful Basis to Information Processing

We process your personal data only when we have a lawful basis. Presently, we have a legitimate interest and, in some cases, your consent as the lawful basis for processing. Our legitimate interest is to deliver the Service to you. We have determined that our processing of your personal data is necessary to deliver the Service to you, and that there is no less intrusive means of delivering you the Service. Finally, we believe that our processing of personal data will not cause unjustified harm in a way that would override our legitimate interest basis as provided under the EU’s General Data Protection Regulations.

In some cases, we may use consent as our lawful basis for collecting and processing certain types of personal information. In such cases, you have a right to withdraw the consent at any time.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

How We Use and Share the Information We Collect


We use the information we collect for things like:

Establishing and managing your account and providing the Service (including communicating with your Neuromotion heart rate monitor)
Providing you with feedback on your progress and activities in the program.
Personalizing the program to meet your specific needs.
Conducting macro-level research and analysis to operate, evaluate and improve our business
Identifying you on the Service


We do not presently sell and have not at any point within the past twelve months sold your or your child’s personal information. We will not share your or your child’s personal information or user data except as described herein or unless you authorize us to. We may provide aggregate usage and demographic information to service partners to help them understand our audience and target their communications accordingly, but not in a way that could identify our users personally.

In the normal course of business Neuromotion may also share your information with individuals (such as employees, contractors and lawyers) and companies (such as our payment processor or push notification delivery service) to perform tasks on our behalf and may need to share certain information with them in order to provide products or services to you. However, our agents do not have any right to use the information we share with them beyond what is necessary to assist us in providing the service to you as described in this Privacy Policy, and have contractually agreed to treat personal information with the same degree of care as we do.

Sometimes we may be required to share your information in response to a regulation, court order or subpoena. We may also share information when we believe it’s necessary to comply with the law. We also may share information to respond to a government request or when we believe disclosure is necessary or appropriate to protect the rights, property or safety of Neuromotion, our customers, or others; to prevent harm or loss; or in connection with an investigation of suspected or actual unlawful activity.

We may also share your information in the event of a corporate sale, merger, acquisition, dissolution or similar event.

How We Store and Protect the Information We Collect

Neuromotion uses reasonable security measures to store and protect the information under our control and appropriately limit access to it. However, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

We use a variety of information security measures to protect your online transactions with us. The Service uses encryption technology, such as Secure Sockets Layer (SSL), to protect your sensitive personal information during data transport.

We want you to feel confident using the Services. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, usage data or other communications will always remain secure. We will notify you by email if we have reason to believe that your personal information has been compromised due to a security breach or used in an unauthorized manner, but by using this Service, you agree to release us from any and all claims arising out of unauthorized use of your information.

Your Choices Regarding the Information We Collect

You may choose to:

  • Access, update and correct your personal information and user settings, and provide you with a copy of your personal information in a portable data format that you can readily share with others
  • Cancel your account or request that we no longer use your information to provide you services
  • Request removal of your personal information or usage data from our Service

To do any of these, simply notify us of this decision by one of these methods:

Data Retention

We will retain your profile information and usage data for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. If you close your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by law. Deactivating your account does not automatically delete your account or usage data from our database, but regardless of any retention policy we will make reasonable efforts to enable you to delete your profile information from our database upon request. However, if certain information has already been provided to third parties, retention of that information will be subject to those third parties’ policies. Additionally, if you have posted your information to other websites or otherwise made it available to the public, you may not be able to remove or edit your information from some internet databases.

Our website may contain links to other websites including those of our service partners, payment processor and other service providers, many of which have their own privacy policies. Be sure to review the privacy policy on any site you are visiting, whether directly or through the Service.

Additionally, we may integrate third party services in to our Service in order to personalize your experience. This policy only covers the use of cookies by Neuromotion. Cookies placed by third party services are governed by the third party terms and privacy policies applicable to those services (which we encourage you to read).

Children’s privacy

Neuromotion is a COPPA compliant Site. Read more about COPPA at the COPPA website. This regulation is designed to protect the privacy of your children. For a child under the age of 13 to use the Neuromotion-provided games his or her parent or guardian must approve the registration.


We will not discriminate against you for exercising your privacy rights. We do not offer financial incentives for the retention or sale of your personal information. Any incentives we offer to our users are offered in exchange for a service.

Using the Services from outside the United States

This Privacy Policy is intended to cover collection of information from residents of the United States and is not intended for users located outside the United States. If you are accessing the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States by us as data controller and as data processor. By signing up for and using the Service you agree to this transfer.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant or involve changes to the way we use personal information, we will notify you by delivering an announcement via our Service or your account email. If you opt out of communications from Neuromotion, you may not receive these notifications, however they will still govern your use of the Service, and you are responsible for proactively checking for any changes. Each version of this Privacy Policy will be identified by its effective date found at the bottom of this page.

Last Updated: February 26, 2020