Last updated November 1, 2023
This Privacy Policy explains how NeoRecall, Inc. (NeoRecall) collects, uses, and discloses information about you when you access or use our website, mobile application, and other online products and services (collectively, the "Services"), and when you contact our customer service team, engage with us on social media, or otherwise interact with us. This policy does not apply to subscription eligibility information we receive from and process on behalf of our enterprise business customers and partners (defined as "Customer Data" in the applicable agreement), but this Privacy Policy does apply to your use of the Services, regardless of your subscription or account type. Additional information for individuals in the EEA, UK, and Switzerland, as well as for California residents, can be found at the end of this Privacy Policy. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
We collect information when you register for an account, participate in interactive features (like by submitting a meditation rating or completing a check-in), fill out a form or a survey, participate in a contest or promotion, make a purchase, communicate with us via social media sites, request customer support, or otherwise communicate with us. The information you may provide includes your name, email, password, street address, payment method information, goals, previous meditation experience, moods and reflections you provide during check-ins, feedback and survey responses, and other information about you included within your messages to us or otherwise provided via the Services. Some users also provide health-related information in connection with providing feedback or other messages to us, and we process that information consistent with the purpose for which it was provided.
When you use our Services, we collect the following information about you:
• Usage Information: Whenever you use our Services, we collect usage information, such as the sessions you use, videos you view or content you listen to, what screens or features you access, and other similar types of usage information.
• Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product description, price, subscription or free trial expiration date, and time and date of the transaction.
• Log Information: We collect standard log files when you use our Services, which include the type of web browser you use, app version, access times and dates, pages viewed, your IP address, and the page you visited before navigating to our websites.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, device identifiers set by your device operating system, and mobile network information (like your connection type, carrier and region).
• Information we Record: On some occasions, we may record phone or video calls with your consent, such as in connection with our coaching program or when you provide us with feedback or market research.
• Information we Generate: We generate some information about you based on other information we have collected. For example, like most platforms, we use your IP address to derive the approximate location of your device. We also use your first name to make an educated guess about your gender and use information about your activity to help determine the likelihood of you continuing to use our Services in the future (which we hope will be the case!).
• Information Collected by Cookies and Similar Tracking Technologies: We use different technologies to collect information, including cookies and web beacons.
We also obtain information about you from other sources, including transaction information from third-party app stores you use to install our app or purchase a subscription, and name and contact information from third-party calendar services. Additionally, if you create or log into your account through a social media service account, we will have access to certain information from that account, such as your name and other account information, in accordance with the authorization procedures set by that social media service. Finally, we may obtain information about you from publicly available sources, marketing and advertising partners, consumer research platforms, and/or business contact databases.
We use the information we collect to:
• Provide, maintain and improve our Services, including debugging to identify and repair errors, and developing new products and services;
• Process transactions and fulfill orders;
• Send you transactional or relationship messages, such as receipts, account notifications, customer service responses, and other administrative messages;
• Communicate with you about products, services, and events offered by NeoRecall and others, request feedback, and send news, gifts or other information we think will be of interest to you (see the "Your Choices" section below for information on how to opt out of marketing messages);
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of NeoRecall and others, including to enforce our agreements and policies. If you feel your transaction was declined in error, please contact us for assistance at contact@NeoRecall.com;
• Comply with the law, such as by processing transactional records for tax filings and other compliance activities;
• Personalize your online experience and the advertisements you see on other platforms based on your preferences, interests, and browsing behavior; and
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards.
We share information about you as follows and as otherwise described in this Privacy Policy or at the time of collection:
• With companies and contractors that perform services for us, including email service providers, payment processors, fraud prevention vendors and other service providers;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including court order, subpoena, or other lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of NeoRecall or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among NeoRecall and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• With your consent or at your direction. For instance, you may choose to share actions you take on our Services with third-party social media services via the integrated tools we provide via our Services.
We also share aggregated or other information not subject to obligations under the data protection laws of your jurisdiction with third parties. For example, we sometimes share aggregate information with research organizations to help facilitate their research.
We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, device identifiers, 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 NeoRecall and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and online services, and better understand your online activity. You can disable cookies used for advertising purposes through our cookie preferences manager. Or, for more information about interest-based ads, including to use ad industry tools to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices (if you are in the EU, please visit www.youronlinechoices.eu/). Your mobile device should also include a feature that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.
NeoRecall is based in the United States and processes information in the United States, which may not provide equivalent levels of data protection as your home jurisdiction.
You may opt out of receiving promotional emails from NeoRecall by following the instructions in those emails or by logging into your account. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
With your consent, we send promotional and other push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Subject to certain limits and conditions provided under law, we honor the exercise of the right of access or deletion for all of our users, regardless of their location. Any NeoRecall user may exercise this right by contacting us at contact@NeoRecall.com.
The sections below apply to you if you use our Services while in Switzerland, the United Kingdom or the European Economic Area (collectively, "Europe"). NeoRecall, Inc. is the data controller for personal data governed by this Privacy Policy.
When we process your personal data we will only do so in the following situations:
• As necessary to perform our responsibilities under our contract with you (like processing payments and providing the products or services you have requested);
• When we have a legitimate interest in processing your personal data, including to communicate with you about changes to our Services, to help secure and improve our Services (including to prevent fraud) and to analyze use of our Services;
• As necessary to comply with our legal obligations; and
• When we have your consent to do so.
We retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.
Subject to certain limits and conditions provided under law, you have the following rights:
• You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or made available in a portable form.
• You also have the right to object to certain processing (like receiving direct marketing), or request that we restrict processing in certain circumstances (like to retain but not further process pending resolution of a claim).
• When we ask for your consent, you may withdraw that consent at any time.
• You have the right to file a complaint regarding our data protection practices with a supervisory authority. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. If you are in the United Kingdom, please see this site for contact details: https://ico.org.uk/global/contact-us/.
If you would like to exercise any of these rights and can't do so directly via the Services or your device, you may contact us as indicated below.
This section provides additional disclosures required by the California Consumer Privacy Act (or "CCPA”). Please see the chart below for a list of the personal information we have collected about California consumers in the last 12 months, along with our business and commercial purposes and categories of third parties with whom this information may be shared. For more details about the personal information we collect, including the categories of sources, please see the "Collection of Information" section above.
Identifiers , such as your name, phone number, email address, social media handle, and unique identifiers (like IP address) tied to your browser or device. Characteristics of protected classifications under state or federal law , such as gender and age. Commercial information , such as your payment information and NeoRecall product or service purchases. Approximate geolocation data. Internet or other electronic network activity, such as browsing behavior and information about your usage and interactions with our Services. Audio, electronic, visual, or similar information , such as profile photo or personal information you may provide during customer support calls and call recordings. Professional, employment, and education information, such as information we collect about teachers and other administrators in connection with NeoRecall Schools Initiative or NeoRecall Health Initiative. Other personal information you provide , including opinions, preferences, goals and previous meditation experience and other personal information contained in product reviews, surveys, or communications. Inferences drawn from the above, such as product interests, and purchasing insights.
Performing or providing our services, such as to maintain accounts, provide customer service, process orders and transactions, and verify customer information. Improving and maintaining our Services, such asby improving our Services and developing new products and services. Debugging , such asto identify and repair errors and other functionality issues. Communicate with you about marketing and other relationship or transactional messages. Analyze usage , such as by monitoring trends and activities in connection with use of our Services. Personalize your online experience , such as by tailoring the content and ads you see on our Services and on other platforms based on your preferences, interests, and browsing behavior. Legal reasons, such as to helpdetect and protect against security incidents, or other malicious, deceptive, fraudulent, or illegal activity.
Companies that provide services to us , such as those that assist us with customer support, subscription and order fulfillment, advertising measurement, communications and surveys, data analytics, fraud prevention, cloud storage, bug fix management and logging, and payment processing. Third parties with whom you consent to sharing your information , such as with social media services or academic researchers. Our advertisers and marketing partners, such as partners that help determine the popularity of content, deliver advertising and content targeted to your interests, and assist in better understanding your online activity. Government entities or other third parties for legal reasons, such as to comply with law or for other legal reasons as described in our Sharing section.
Subject to certain limitations and exceptions, the CCPA provides California consumers the right to request to know more details about the categories and specific pieces of personal information, to delete their personal information, to opt out of any "sales" that may be occurring, and to not be discriminated against for exercising these rights.
We do not "sell" the personal information we collect (and will not sell it in the future without providing a right to opt out). We do allow our advertising partners to collect certain device identifiers and electronic network activity via our Services to show ads that are targeted to your interests on other platforms. To opt out, you can use our cookie preferences tool to disable ad trackers on our website and can adjust your mobile device settings to limit ad tracking via the mobile app.
California consumers may make a rights request by emailing us at contact@NeoRecall.com.
Notice of Financial Incentives: We offer various financial incentives. For example, we may provide incentives to customers who participate in a survey or provide testimonials. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name and email address) and information about your experiences using our Services. You can opt into a financial incentive by following the sign-up or participation instructions provided. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.
NeoRecall strives to make this privacy policy accessible in line with the World Wide Web Consortium's Web Content Accessibility Guidelines, version 2.1.
If you have any questions about this Privacy Policy, please contact us at: contact@NeoRecall.com.