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1.0 Introduction

1.1 At NeuroTechnology, LLC, we are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 In this policy, "we", "us", and "our" refer to NeuroTechnology, LLC.  More information about us can be found in Section 6 below.

1.4 At NeuroTechnology, LLC, we want to make sure that the website we operate looks as good as possible, but also is easy for you to use. To help us to do this, our website uses cookies.  Cookies help us to assess how you use our website and also how we can improve our website. This means we have the information we need to regularly evaluate whether our website really meets your needs. Some of the cookies we use improve the functionality of our website, so if you choose to disable cookies on your browser, you might find that you can't access some aspects of our website, or that parts of the website don't function in the way that you might expect them to.  Please refer to section 5 and our cookie policy for further information.

2.0 How we use your personal data

2.1 In this section we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data;

(c) the legal bases of the processing.

2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and Yandex.Metrica. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely to monitor and improve our website and services.  The information we collect via Google Analytics and Yandex.Metrica does not typically contain information that could identify you personally.

2.3 We may process your account data ("account data"). The account data may include your name, address, email address and contact telephone number(s). The source of the account data is you or your representative. We may process this account data for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the administration of our website and business and providing our services to you.

2.4 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

2.6 We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details including name, address, telephone number and email address, your card details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website, business and services.

2.7  We do not retain your payment card details, including security information, for any period longer than is necessary to process your payment.  Card payment details that are processed electronical are done through secure payment gateways which comply with current laws of the Russian Federation. Further information about our payment providers can be found in section 3.1 below.

2.8 We may process information contained in, or relating to, any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and communications with users.

2.9 We may process information you provide to us when you access our live chat enquiry service (“live chat data”).  This data may include your name, telephone number, email address, IP address, approximate location (based on your IP address), details of your search history at that time on our website, and information about your browser, platform and device.  The live chat data may be processed for the purpose of assisting you with your enquiry via our live chat service.  The legal basis for this processing is our legitimate interests, namely providing a live chat facility to you, to help answer your queries about our products, services and business.

2.10 We may process information you provide to us when you use pop-up notifications and services on our website (“pop-up data”).  This data may include your name, address, email address, phone number and your IP address.  This pop-up data may be used for the purpose of enabling your subscription to our newsletter and access to special offers.  The legal basis for processing your subscription to our newsletter via pop-up data is consent.  The legal basis for processing your information to access special offers is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. 

2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.13 In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.14 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.0  Providing your personal data to others

3.1 Financial transactions relating to our website and services are handled by our payment services providers, Yandex.Checkout. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at:
Yandex.Checkout Privacy Policy

3.2 In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.0  Amendments

4.1 We may update this policy from time to time by publishing a new version on our website.

4.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

5.0 Cookies

5.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

5.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

5.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

5.4 Blocking all cookies will have a negative impact upon the usability of many websites.

5.5 If you block cookies, you will not be able to use all the features on our website.