Qneuro wants you to be familiar with how we “process” (i.e., collect, store, use and disclose) information from and about you in connection with the Services (as defined below). This Privacy Policy applies to the information processed by Qneuro Inc. (“Qneuro,” “we,” or “our”) or any third parties acting with our authorization or otherwise provided to us by third parties about you, in each instance, in connection with your use of (a) www.qneuro.com and all corresponding domains, subdomains, web pages and websites associated therewith (the “Site”); (b) all mobile and software applications made available by us from time to time (e.g., Apple iOS Apps, etc.) (the “Apps”); (c) any games, contests, quizzes, or other interactive learning tools (“Games”); and (d) any other content, applications, features, functionality, information and services offered by us though the Site or the Apps, including, without limitation, Quiz Scene (the foregoing subsections (a) through (d) are collectively referred to herein as the “Services”). You should also review the Terms of Service Agreement, which governs your use of the Services. Any capitalized terms that are not defined in this Privacy Policy shall have the meaning ascribed to them in the Terms of Service Agreement. This Privacy Policy will remain in full force and effect, even if your use of the Services or any particular feature offered in connection therewith terminates, expires or is deactivated or suspended for any reason. We will either rely on our legitimate interest or our need to perform under a contract to process your information or you will be asked to affirmatively consent to our processing of your information, all in accordance with the terms and conditions of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access and/or use the Services or any features, activities, products or services offered through or in connection therewith.
We collect some personal information that relate to your interaction with the Games or other information about you when you visit or use our Services. The information and data we may process depends on your interaction with us. The key types of information that we may process include the following:
Registration Information: In order to access and use certain features, content, folders or functions of the Services, you may need to register for a User Account. When you create a User Account, we will collect personal information as necessary to offer and fulfill the Services (e.g., to give you access to the Games) you request. Depending on the Services you elect to use, we may ask you to provide your name, email address, school affiliation, and/or date of birth. If you choose not to provide some of this information, you may not be able to use all of the features of the Services.
Payment Information and Purchase History: If you purchase an upgraded membership subscription, products or services on or through our Services, your payment information (e.g., credit or debit card number, card type and expiration date and address associated with such credit or debit card) and additional information to fulfill the services or deliver the products (e.g., name, date of birth and shipping address) may be processed by us and/or third party payment processors. We also process the details of any upgraded membership subscription or purchased services or products, including the date of purchase, subscription status or subscription price.
Service Interaction Information: When you use the Services, we may collect and store information related to your use of the Services, including your search queries, clicks and site navigation information, your answers to Question Sets, comments you post, classes you have joined, high scores you have achieved, study activity, browser type, language preference and time zone, referring site, date and time of each visitor request, ISP or mobile operator, log-in and log-out times or IP address.
Third Party Service Information: If you access the Services by logging in using your account credentials from a third-party owned or operated platform/service (e.g., Apple (iTunes, etc.),Google, Facebook, Twitter, LinkedIn, etc.) (each, a “Third Party Service”), post content from the Services to a social network, or use various social media features (e.g., “Like” button), we may process certain information from the Third Party Service, such as your username, “likes”, location, birthday, email address, comments and reviews, direct messages you may send to us, interests, friends, status updates and other information you provided to the Third Party Service in connection with your account. Depending on your account and privacy settings, we may also be able to see information that you post when using these Third Party Services whether or not you are using our Services. The information you post or provide to Third Party Services, as well as the controls surrounding these disclosures are governed by the respective policies of these third parties.
[Personal Data You Choose to Provide for Marketing or Additional Services: We may process personal data that you choose to provide to us when you elect to participate in optional Site-features or Services. For example, if you sign up to receive newsletters, marketing emails, promotions or other communications regarding the Services and/or promotions from our preferred third-party products or services, participate in contests, surveys and other promotions related to the Services, we may process your name, email address, mailing address, gender, interests and phone number in order to provide the additional features or Services. We will make clear what information we may process as a result of your engagement with the optional Site-features or Services.]
We may process your personal information (depending on your interaction with us) for a variety of reasons that are permitted under data protection laws and in accordance with this Privacy Policy, which may include the purposes described below. If we use your information for other purposes than those mentioned below, we will notify you of these purposes before using your information and obtain your consent where necessary. The legal bases outlined below are the legal bases upon which we will rely to process the personal data of end users located in the European Union (“EU”).
To fulfill our contractual obligations under an existing agreement with you or in anticipation of entering into an agreement with you, including:
To allow you to upload Question Sets;
To communicate with you about your User Account, use of Question Sets and use of the Services;
To respond to requests for information and services, including services from a third party;
To communicate and resolve issues with other users of the Services;
To fulfill orders or post Question Sets and provide you with products and services you have requested and/or paid for; and
To enforce your legal rights under an agreement.
To meet and fulfill our legitimate business interests, including:
To manage our business needs, such as monitoring, analyzing, modifying and improving the Services’ functionality and performance;
To provide you with information and advertisements about services similar to the Services and opportunities presented by partners that are relevant to the Services;
To prevent fraud and abuse on and unauthorized access to the Services; and
To determine which features and functionality of the Services users like best to help us operate, enhance and improve the Services.
To comply with our regulatory and legal obligations or to enforce our legal rights, including:
To meet reporting requirements (e.g. filing tax forms);
To retain documents and information related to a legal action;
To enforce the Terms of Service Agreement; and
To report data breaches or unauthorized access to the Services.
With your consent*, including, without limitation:
To provide location-specific functionality, features, services or offers;
To communicate to you and others about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners;
To market to you by delivering marketing materials about Qneuro, our products and services, as well as the products and services of unaffiliated third party businesses; and
For other purposes for which you may grant consent.
We will not share your personal information with others except in the following circumstances:
[Our Group Entities: We may disclose your personal data to our group entities that are affiliates and/or subsidiaries or parents of Qneuro in order to provide you with tailored offerings, educational information, products, services and communications.]
Service Providers: We may partner with other companies to help us operate certain aspects of our businesses, including the hosting of the Site and Apps, operation of our technology infrastructure, processing of payments, providing us with anonymized and aggregated analytics, and fulfillment certain of the services or products you request from us. We carefully select such third party operators, merchants, website hosts, service providers and participants to your transactions, for the purpose of (1) assisting with facilitating transactions on or through the Services, (2) providing information technology and customer service assistance, and (3) providing, offering, supporting, administering, maintaining and enabling the Services.
Corporate Transactions or Events: We may disclose your personal information in connection with a merger, sale of substantially all of our assets, transfer, corporate reorganization or other disposition of our business.
Pursuant to Law, Rule or Regulation: We may share or disclose your information with other parties as we deem necessary or appropriate under applicable law, rule or regulation.
To Fulfill Your Requests: If you elect to use certain features, folders or functions, including, enabling you to upload Question Sets to the Services, we may use your information to fulfill your request.
Information You Elect to Make Public: We may share or make available the information you elect to make public (e.g., information you make public through your User Account, classes you have joined, high scores you have achieved, or Question Sets you have studied or taken, comments you post, testimonials you make, etc.).
With Your Consent: If we do not process your personal information in accordance with our legitimate interest or based on a contractual obligation we have with you, we may share or disclose your personal information if you provide us with your affirmative consent.
We strive to provide you with as many choices as possible to access, review, correct, update, suppress or otherwise limit our use of the information you have provided or asked a third party to provide to us, including:
User Account: If you have registered for a User Account to assist us with providing the Services, you may have the ability to update, delete and correct your User Account information. To update, delete and/or correct information in your User Account please email us at support@qneuro.com.
Contact Information: If you provided contact information in connection with your use of the Services, you may have the ability to update, delete and correct your contact information. To update, delete and/or correct information in your contact information please email us at support@qneuro.com.
We will try to comply with your request(s) as soon as reasonably practicable, but no later than within the time-frame required under applicable law.
If you are an EU citizen or reside in the EU, you may have certain rights with respect to the personal information you provided to us. To the extent permitted by applicable data protection laws, you may:
Access or modify your personal information;
Object, on grounds relating to your particular situation, at any time to the processing of your personal information if the legal ground we are relying on is our legitimate interest or in the public interest;
Request that your personal information be corrected if such personal information proves inaccurate or incomplete;
Request that your personal information be erased if it is no longer necessary for the purposes for which it was processed;
Withdraw your consent to, or object to, the processing of your personal information if we meet no other legitimate basis for such processing or your personal information has been unlawfully processed;
Restrict the processing of your personal information if you contest its accuracy or the lawfulness of our processing, we no longer need it but you need it for a legal claim or you have objected to its processing and await verification of our legitimate grounds for processing it;
Ask to stop receiving our marketing communications. If you opt out of marketing emails, you will continue to receive messages from us about your relationship with us where permitted by law;
Under certain circumstances, have your personal information transferred to another company;
Withdraw any consents that you have previously provided to allow us to process your personal information; or
Lodge a complaint to the relevant data protection authority.
If you wish to exercise any of these rights please email your data subject request to us at support@qneuro.com Please note that some requests may require you to verify your identity.
While no data transmission over the Internet is 100% secure from intrusion, we maintain and have implemented physical, electronic, technical and procedural security policies and measures to protect the personal information that we collect, use and/or store, which are consistent with applicable privacy and security laws. These policies and measures are designed to prevent against loss, misuse, unauthorized access, modification and disclosure and unlawful destruction of your personal information. However, regardless of our efforts, it is possible that third parties may unlawfully intercept or access transmissions or private communications. We also limit access to the Services by our own employees, contractors, service providers and those individuals who are authorized for the proper handling of such information. We request that our third party contractors and service providers follow similar standards of security and confidentiality. However, regardless of our efforts, no one can guarantee the complete safety of your information.
While we are dedicated to securing your personal information and our systems and Services, you are responsible for securing and maintaining the privacy of your User Credentials and verifying that personal information we maintain about you is accurate and current.
We access, retain, store and use personal information for the least amount of time necessary pursuant to our relationship with you (e.g., to provide you with or access to the Services), in accordance with our data retention policies and applicable law. We do not collect more personal information than is necessary to fulfill our obligations to you or at law or for purposes stated in this Privacy Policy. Please be aware that even after you cancel your User Account, copies of certain information from your User Account or that you uploaded to the Service may remain viewable under certain circumstances. For fraud detection or to comply with applicable law or our internal security policies, we may also retain backup information related to your User Account or the information you previously uploaded to the Service on our servers for some time after cancellation. Further, you acknowledge that it is not always possible to completely remove or delete all of your information due to technical constraints, contractual, financial or legal requirements.
If you are a resident of the State of California, we provide you with information above on how to exercise your choice options such as your right to opt-out or opt-in for use of your personal information by third parties for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year. If you are a California resident and wish to request information about how to exercise your third party disclosure choices or other rights afforded under the law of the State of California, please contact us at support@qneuro.com or reach out to us by postal mail to the address set forth in Section 11 below. All requests must be labeled “Your California Privacy Rights” in the topic line or on the envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights,” include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly or that do not have complete information.
We do not knowingly collect information via the Services from children under the age of 13 or other individuals who are not legally able to use the Services. However, if a user under the age of 13, with consent from his or her parent or guardian, requests access to the Services, we may accommodate them by offering a limited feature set and restricted website experiences that removes certain features. We offer this restricted experience via a “Child Account” for accounts of all users below the age of 13 or below the age of majority where applicable under local law. To create a Child Account we collect only the minimum amount of personal information necessary to provide the Services and only require the user to provide a date of birth, user name and email address of a parent or guardian. If we obtain actual knowledge that we have collected personal data from someone under the age of majority who does not have a Child Account, we will promptly delete it, unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from someone under the age of majority, please contact us at support@qneuro.com. For users in the United States, please also visit ftc.gov for information from the Federal Trade Commission about protecting children’s privacy online.
From time to time, we may modify this Privacy Policy to reflect industry initiatives, third party requirements or changes in the law, technology, our information collection and use practices or the features and functionality of the Services, and such modifications shall be effective upon the posting of a revised Privacy Policy. When we change this Privacy Policy in a material way, we will provide you with notice of such changes. Your continued use of the Services after we upload a revised Privacy Policy signifies your acceptance of the revised Privacy Policy. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. We may continue to process your information based on our legitimate interests or in order to fulfill our obligations under a contract and/or may also seek your affirmative consent to the terms of the updated Privacy Policy.
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and some of our affiliates, partners, servers, vendors and service providers may not be located in your jurisdiction and may also be located outside of the European Economic Area and Switzerland. Further, the Services are hosted in and managed from the United States of America (“U.S.”). If you visit the Services from a location outside the U.S., please be advised that any information you provide may be processed in and/or transferred to or from the U.S. or other jurisdictions, where privacy protections may not be as comprehensive as those in your jurisdiction. If you are an EU citizen or resident in the EU, we will transfer your personal information to the U.S. in accordance with EU data protection law requirements by using standard contractual clauses that have been approved by the European Commission or other appropriate means.
Please note that transfers of personal information outside of the European Economic Area and Switzerland may also be necessary in order to perform our obligations under a contract with you (including under these Terms), to fulfill a request made by you, to meet a legal or regulatory obligation and/or through obtaining you express consent. If you make transactions with parties outside the European Economic Area or Switzerland, we are required to transfer your personal information with those parties in order to provide the requested service to you. If you wish to gain more information about such transfers, please contact us support@qneuro.com
Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority. If you have questions about this Privacy Policy, please contact us at:
Email: support@qneuro.com
Mail:
Qneuro Inc.
Attention: Sivaramakrishna
460 Goddard
Irvine, CA 92618 USA
This Privacy Policy is effective immediately.