Endorsed by the American Senior Fitness Association:
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Privacy Policy
NeoCORTA is committed to protecting the privacy of our users' personal information. This Privacy Policy will tell you what information we collect, how it is protected and how it is used.
This Privacy Policy applies to information that users transmit to NeoCORTA through any websites owned or operated by (or on behalf of) NeoCORTA, including www.neocorta.com and www.brainfitness.com (collectively, the "Sites"), through any version of the NeoCORTA Brain Fitness Check-up (paper or electronic), which includes the NeoCORTA Brain Fitness Questionnaire and the NeoCORTA Personal Brain Fitness Report (collectively the "Check-up").
The NeoCORTA Web site may contain links to other sites. Once you enter another Web site (whether through an advertisement, service, or content link), be aware that NeoCORTA is not responsible for the privacy practices of these other sites. We encourage you to look for and review the privacy statements of each and every Web site that you visit through a link on NeoCORTA.
Please direct any questions regarding this Privacy Policy to us by email at service@neocorta.com.
WHAT INFORMATION WE COLLECT
Personally Identifiable Information
We collect personally identifiable information on our Sites and through our Software, including in the following ways:
• When you register for or purchase the Brain Fitness Check-up;
• When you send email through the Sites;
• When you use the NeoCORTA Brain Fitness Check-up
The types of information collected may include your Internet Protocol (IP) address, name, credit card information, billing and shipping addresses, email address, telephone number, and additional contact and transaction-related information, as well as any additional information you choose to include in communications to us.
We consider each of the above types of information to be "Personally Identifiable Information" because it is (or it is associated with) individually identifiable information about you. Personally Identifiable Information as used in this Privacy Policy does not include Protected Health Information (defined below).
Protected Health Information
"Protected Health Information" or "PHI" means "individually identifiable health information" that we create or receive as a "covered entity," as defined in the privacy and security rules under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). NeoCORTA will use or disclose PHI only as permitted by those rules and other applicable law. For example, NeoCORTA will not use or disclose your PHI to market products or services to you. If you receive marketing or promotional information from NeoCORTA this will be as a result of our use of your Personally Identifiable Information received by us independent of any PHI we receive about you, and in accordance with the terms of this Privacy Policy.
Other Information
Like many websites we use "cookies" and other standard web technology to collect information for our own use.
A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie and to permit you to refuse it. In some cases refusing a cookie will hamper your navigation of our Sites.
Cookies make it easier for you to use the Sites and for us to offer opt in and opt out opportunities, and they enable us to follow your navigation through the Sites and customize it to your interests. They allow us to remember your identity and preferences so we can display content appropriate for you and your interests and so we can better market and sell our products, services, and software to you.
The information is only used to help manage our Sites and deliver products and information to you.
HOW YOUR INFORMATION IS PROTECTED
Digital Information
We use SSL encryption, firewalls and self-updating anti-virus software designed to protect your personal information from unauthorized access. In addition, user purchase information is encrypted.
Paper-based Information
Paper versions of the Brain Fitness Check-up are stored under lock and key at NeoCORTA's corporate headquarters. In cases where paper copies of an individual's Personal Brain Fitness Report are mailed to one of our partner organizations, each report is sent in a sealed envelope.
HOW YOUR INFORMATION IS USED
We use your Personally Identifiable Information (and at times other information we collect) to:
• Authenticate your visits;
• Create your Personal Brain Fitness Report;
• Send you information and products, including software updates; or
• Help us make you aware of and provide services and products that may be of interest to you.
We also use the information to manage and improve our Sites.
We may also use your Personally Identifiable Information to contact you with our newsletters, marketing or promotional materials, coaching information and customer support materials or notices about new products and services that may become available and to customize and deliver that information to you.
We also disclose Personally Identifiable Information as permitted or required by federal, state or local law or as required by subpoena, search warrant, or other legal process.
As our business evolves, we may sell, transfer or otherwise share some or all of our assets, including information provided by you, in connection with a merger, reorganization or sale of some or all of our assets or in the event of bankruptcy. In any such event, Personally Identifiable Information and other information may be one of the assets transferred. We will post notice before personally identifiable information is transferred and becomes subject to a different privacy policy. When feasible, we will take commercially reasonable steps to limit the disclosure of Personal Identifiable Information during the preparatory stages of a change of ownership, and in all cases Protected Health Information will be disclosed only as permitted by applicable law.
CHOICE
You are not required to register to gain access to many areas of the Sites. However, if you use the Brain Fitness Check-up (paper-based or electronic), we will collect your Personally Identifiable Information as described in this Privacy Policy and use it to the extent necessary to provide products, information and services you request.
MORE ON PRIVACY
Children's Online Privacy Protection
NeoCORTA understands the importance of protecting children's privacy, especially in an online environment. The Sites and the Software are not designed for or directed at children. Use of the Software is currently limited to adult environments. It is our policy not to knowingly collect or maintain information about anyone under the age of 13.
Refer-A-Friend
If you choose to use our referral service to tell a friend about our Sites or our products or services, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Sites. NeoCORTA stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at service@neocorta.com to request that we remove this information from our database.
Links to Third Party Websites
The Sites may contain links to third party websites. We assume no responsibility for the information practices of those websites. We encourage visitors to review each website's privacy policy before disclosing any personal information on that website.
Phishing
We do not and will not, at any time, request your Personally Identifiable Information or other information in a non-secure or unsolicited e-mail or telephone communication. Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is one of our priorities. For more information about phishing, visit the Federal Trade Commission at http://www.ftc.gov/bcp/edu/pubs/consumer/alerts/alt127.pdf
Access to Data
Registered users may contact us with requests that we delete their Personally Identifiable Information from our systems and we will attempt to accommodate such requests. If any such information is deleted from our systems, your account may become deactivated. In any event, we may retain an archived copy of your records as required by law or for legitimate business purposes. See below for privacy contact information.
International Users
NeoCORTA is located in the United States of America. If you live outside of the United States, by visiting our Sites and providing us with data, you acknowledge and agree that your data may be transmitted to the United States which is outside your resident jurisdiction. Furthermore, you acknowledge and agree that such data may be stored and processed on servers located in the United States.
CHANGES TO THIS POLICY
This Privacy Policy may be updated from time to time as our services change and grow. We will indicate any such changes at the privacy link at the bottom of our home page. The most current version of the Privacy Policy can be found at http://www.neocorta.com/about/privacy.php.
CONTACT
We welcome inquiries or comments about our Privacy Policy and any queries or concerns about NeoCORTA by email at service@neocorta.com.
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