1. INTRODUCTION
Neurogram LLC (“Neurogram”) values the trust our users place in us when they give us access to their personally-identifiable information (“Personal Information”) and their voice requests when they use our Natural Language Calculator Flash.  This Privacy Policy (“Policy”) describes how we work to maintain that trust.

Neurogram has created this Policy in order to outline our collection, use, and sharing of information you provide to us when you access or use Flash and our website. For the purposes of this Policy, any references to “we,” “our,” or “us” shall mean Neurogram.
 
Please note that we reserve the right to review and update this Privacy Policy from time to time.  Accordingly, each time you access or use Flash, you should check our updated Policy and review any changes since you last accessed or used the app.  If you access or use the app after an updated Privacy Policy is published, you will be deemed to have agreed to the amended Policy.

BY ACCESSING AND USING THIS SITE, YOU REPRESENT AND WARRANT THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THE TERMS OF, THIS PRIVACY POLICY.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THIS SITE OR OUR APP Flash.

2. INFORMATION THAT WE COLLECT ABOUT YOU

Information Provided by You Upon accessing our app
Before you can access our mobile app, you are requested to login using your pre-existing google account created for using your android phone. This is the only information we collect for you to use our app. You have a choice of not providing your pre-existing google credentials, in which case you might not be able to use our app.

Information Provided When You Contact Us
We may collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Site.  We may collect one or more of the following types of Personal Information when you contact us with a question or comment, or request information from us about our product and services:

1. Name
2. E-mail address
3. Phone Number
4. School Name
5. City, Country

Passively Collected Information
When you access and use our Site, we may automatically collect and retain certain types of information, including your computer or device’s internet protocol (IP) address and other technical information about your computer or device and website usage, such as your browser type and version, time zone setting, and operating system and platform.

We also use cookies on our Sites; for more information, please see the Cookies and Other Tracking Technologies section below.

​We may collect certain additional information when you access our Site with a mobile device or with Flash IOS and Android mobile apps. This information may include location, device type, unique device identifier, operation system, and other app-specific user data. This data is analyzed to help us create a more user-friendly mobile experience. You may restrict collection of certain data, like location by changing the setting preferences on your mobile device.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE
We and our service providers use cookies, beacons, embedded scripts, and local shared objects in connection with the Site.

●      Cookies are small text files that are stored on your computer or device when you visit our Site.  Cookies allow a website to recognize a particular device or browser. The use of cookies is a standard practice among websites to collect information about visitors’ activities while using the website.

●      Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on our Site and typically work in conjunction with cookies to assist our site with the automated collection data on user behavior. Neurogram will not be able to personally identify you in connection with these practices.

●      An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.  The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active only while you are connected to the Site and is deactivated or deleted thereafter.

●      Local Shared Objects.  Local shared objects (or Flash cookies) are pieces of data that websites which use Adobe Flash may store on a user’s computer or device.  Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity use local shared objects.  Various browsers may offer their own management tools for removing local shared objects. In addition, you may manage Flash cookies by clicking here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

The above technologies are used in analyzing trends; administering the Site and its features and services; tracking users’ movements around the Site; and to gather demographic information about our user base as a whole.  We may receive reports based on the use of these technologies on an individual as well as aggregated basis.

We use cookies to remember users’ settings, market products and services to users, and for authentication purposes.  To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept, or delete cookies from our Site at any time.  The “Help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies; how to have the browser notify you when you receive a new cookie; or how to disable cookies altogether.  Please note that if cookies are disabled or removed, not all features of our Site will operate as intended.


Third-Party Analytics.  We may also use service providers, such as Google Analytics, that may use cookies or other technologies to collect information about your online activities across this and other sites over time for non-advertising purposes such as those described above.  To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, you may visit http://www.google.com/intl/en/policies/privacy/partners/.

4. WHAT WE DO WITH THE INFORMATION WE COLLECT

●      General Uses.  We also use the information we collect to manage, analyze, develop, customize, and improve our app or our site as well as our products and services.

●      Information Provided When You Contact Us.  We may use this information to understand and respond to your question or comment.

●      Passively Collected Information.  We use passively collected information to monitor and maintain the performance of our Site; analyze trends, usage, and activities in connection with our services; validate users and ensure their technological compatibility with users; optimize our marketing efforts; and to provide our products and services to you, including analyzing your Gameplay Data and developing your Trait Profile.

●      Aggregate Data.  We may use aggregate our user’s Personal Information and passively-collected information to create aggregate data which cannot be used to identify you (“Aggregate Data”). For example, Aggregate Data may include data that describes the general demographics, usage, Gameplay Data, or other characteristics of a Site’s users.  We reserve the right to use, transfer, and/or sell Aggregate Data about the Site’s users for any lawful purposes. We also reserve the right to use such aggregate information in collaboration with outside researchers to measure and quantify the effectiveness of our products and services.

●      Public Profile.  If you select Public in your Privacy Settings tab on your Account Profile, we may use your information to match you with potential employers or job openings.

●   Other Purpose.  We may use your information for any additional purpose which you separately authorize in the course of accessing and using our Site.

5. WITH WHOM WE SHARE THE INFORMATION WE COLLECT

Personal Information of our users is an integral part of our business.  We reserve the right to share your Personal Information with third parties as described below.  We also reserve the right to transfer and/or sell other types of data, including aggregate or de-identified data derived from Personal Information, for lawful purposes in our discretion.  Note that we do not share Personal Information with third parties for their direct marketing purposes.

●      Service Providers.  We, like many businesses, sometimes hire other companies (“Service Providers”) to perform certain business-related functions.  Examples include customer service, maintaining databases, data storage, cloud services, and hosting services.  When we employ a Service Provider to perform a function of this nature, we provide it with the information that it needs to perform its specific function, which may include Personal Information and other information that you provide to us via the app or our site.  These Service Providers are authorized to use your information only as necessary to provide these services to us.

●      Legal Requirements.  We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena or similar legal obligation; (b) protect and defend our rights or property; (c) act in urgent circumstances to protect the personal safety of users of our app, our site or the public; (d) protect against legal liability; or (e) or as otherwise required or permitted by law.

●      Other Third Parties.  We may disclose your information to other third parties with your prior express consent.

You hereby consent to our sharing of your Personal Information and other information for the above purposes.

EU Residents – International Transfers of Personal Information.  The Personal Information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) in reliance on a variety of compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your Personal Information, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7. YOUR CHOICES REGARDING YOUR INFORMATION

Accessing, Correcting, and Updating Your Information
Please email us at support@neurogramai.com with information necessary for us to process your request.  We will respond to your request within a reasonable timeframe.  We may need to verify your identity before granting access to Personal Information in our custody or control.

Deactivating Your Account
If you wish to deactivate your account or reactivate your deactivated Account, please email us at support@neurogramai.com with the email address.

A deactivated Account does not mean that all of the information associated with your Account is expunged from our systems, although such information will now no longer be readily available to you.

Deleting Your Information
You may request to delete your Personal Information by emailing us at support@neurogramai.com with information necessary for us to process your request.  Note that any deletion request will be subject to our Retention Policy below.

Note that because some of our Games are designed to test memory and instinctive behavior (which can be skewed through subsequent gameplay), once you start or complete the Games, your Gameplay Data and Trait Profile cannot be reset, amended, deleted, or overridden for a period of 12 months after you have completed the Games.

Our Retention Policy

We may retain your information for as long as your Account is active or as long as necessary to provide you with our services, comply with our legal obligations and regulatory requirements, preserve and protect our rights as allowed by law, resolve disputes, maintain security, prevent fraud and abuse, and enforce our agreements (including our End User Agreement).

In accordance with our obligations and requirements under local law, we must retain your information for a period of 2 years following the date of your last recorded assessment. As a result, if you request deletion of any information prior to this 2-year anniversary, we must wait until the 2-year period has passed, after which we will process your deletion request.  If you do not have any recorded assessments during the last 2 years, then we will process your request within 10 business days of receipt.

Even if we are obligated to retain certain information, once you delete your Account or request deletion of your Personal Information, your Personal Information will cease being visible to third parties through our Site, regardless of whether you selected Public or Limited through the Privacy Settings tab of your Account profile.  

As discussed above, we may aggregate our user’s Personal Information and other information to create de-personalized Aggregate Data which cannot be used to identify you.  We will retain such Aggregate Data even after any Personal Information deletion requests have been processed.

8. MISCELLANEOUS

Other Websites.  Our Site may contain links to third-party owned and/or operated websites or mobile applications.  We do not own nor control these third-party websites or mobile applications, and accordingly assume no responsibility for the information practices of those sites or apps.  We suggest that you review their privacy, security, and data collection and distribution policies, if any, prior to providing such websites or apps with any information.

Login.  You can login to our mobile app with your pre-existing google account credentials of your android phone.  This service will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign-up form.  Please note that your relationship with Google or any other third-party is governed solely by your agreement with such third-party.

Security.  The security of your Personal Information is important to us.  We take commercially reasonable steps to help protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.  For example, we use one or more of secure socket layer (SSL) encryption, firewalls, and self-updating anti-virus software. Your Personal Information will be stored in the United States and will be subject to laws applicable in that country. While we take all steps, we consider appropriate, to protect your data, unfortunately, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services.  

Minors.  Students under the age of 18 who plan to use our vKalc® app should do so with the consent of their parents or guardian. As we mentioned before, we do not plan to collect any information other than the pre-existing google account information to login to our app and use it.​

Contacting Us.  The Contact Us link on the Site contains an e-mail link that allow you to contact us directly with any questions or comments that you may have.  If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us at privacy@neurogramai.com