Privacy Policy
Last Updated: April 1, 2025
This Privacy Policy describes how Neurithm ("we", "us", or "our") collects, uses, and discloses your personal information when you use our devices, applications, websites, and services (collectively, the "Services").
1. Information We Collect
1.1 Personal Information
We may collect the following types of personal information:
- Contact information (such as name, email address, and phone number)
- Account credentials (such as username and password)
- Payment information (such as credit card details and billing address)
- Demographic information (such as age, gender, and location)
- Profile information (such as profile picture and preferences)
1.2 Device and Usage Information
When you use our Services, we may automatically collect:
- Device information (such as device type, operating system, and unique device identifiers)
- Usage information (such as how you use our Services and interact with our content)
- Log data (such as IP address, browser type, and pages visited)
- Location information (such as general location based on IP address)
1.3 EEG and Biometric Data
When you use our Neurithm device, we collect:
- Electroencephalogram (EEG) data from the device's sensors
- Derived metrics (such as attention, relaxation, and sleep quality scores)
- Session information (such as duration, time, and activity type)
2. How We Use Your Information
We use the information we collect for various purposes, including:
- Providing, maintaining, and improving our Services
- Processing transactions and managing your account
- Personalizing your experience and delivering content tailored to your interests
- Communicating with you about our Services, updates, and promotions
- Analyzing usage patterns and trends to enhance our Services
- Protecting the security and integrity of our Services
- Complying with legal obligations and enforcing our terms
2.1 EEG and Biometric Data Usage
We use EEG and biometric data specifically for:
- Providing real-time feedback and insights about your brain activity
- Generating personalized recommendations and reports
- Improving our algorithms and the accuracy of our metrics
- Research and development of new features and services (in anonymized form)
3. How We Share Your Information
We may share your information in the following circumstances:
- With service providers who perform services on our behalf
- With business partners with your consent
- In connection with a business transaction (such as a merger or acquisition)
- To comply with legal obligations or protect our rights
- With your consent or at your direction
3.1 Sharing of EEG and Biometric Data
We treat your EEG and biometric data with special care. We will only share this data:
- In anonymized or aggregated form that cannot reasonably identify you
- With third-party applications that you explicitly connect to your account
- With researchers or partners with your explicit consent
4. Your Rights and Choices
Depending on your location, you may have certain rights regarding your personal information:
- Access and portability: You can request a copy of your personal information
- Correction: You can request that we correct inaccurate information
- Deletion: You can request that we delete your personal information
- Restriction: You can request that we limit how we use your information
- Objection: You can object to certain uses of your information
- Withdrawal of consent: You can withdraw consent where processing is based on consent
To exercise these rights, please contact us at privacy@neurithm.com. Please note that some of these rights may be limited where we have compelling reasons to continue processing your information.
5. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include:
- Encryption of sensitive data in transit and at rest
- Regular security assessments and penetration testing
- Access controls and authentication mechanisms
- Employee training on data protection and security practices
- Incident response procedures