1. Who We Are
This Privacy Policy describes how Neuroana Pty Ltd (ACN 651 299 393, ABN 94 651 299 393), registered in Australia and located at 142 Palmerston Street Perth 6000 WA.We collect, use, and protect your personal information when you use our mobile application (Companion) and related services.
We comply with the Australian Privacy Principles (APPs), the EU General Data Protection Regulation (GDPR), the UK Data Protection Act 2018, the California Consumer Privacy Act (CCPA), and other applicable international privacy regulations.
By downloading or using the App, you agree to this Privacy Policy.
2. Information We Collect
We collect only the data necessary to provide and improve the App’s experience.
A. Information You Provide
- Account information: name, email address, or login credentials (if applicable).
- Feedback or messages: if you contact us or respond to prompts.
- Optional input: reflections, responses, or conversation entries shared through the App.
B. Automatically Collected Information
- Device details: model, OS version, time zone, and language.
- Usage analytics: feature interactions and session statistics (non-identifiable).
- Performance data: app errors, crash logs, and diagnostics.
C. Sensitive or Neural Data (if applicable)
If the App processes brainwave, emotion, or cognitive signals, such data:
- Is processed on-device whenever possible,
- Is anonymized or pseudonymized before transmission, and
- Is never shared with advertisers or used to identify individual users.
3. How We Use Your Information
We use collected information to:
- Provide and maintain App functionality.
- Improve user experience and personalization (based on your consent).
- Respond to support requests or feedback.
- Ensure system integrity and prevent misuse.
- Conduct anonymized research to enhance wellness and neurofeedback insights.
We do not sell, rent, or trade your personal information under any circumstances.
4. AI Data Usage & Model Interaction Disclosure
This App includes AI-powered conversational or emotional response features designed to support wellness and self-reflection.
A. How AI Processes Your Input
When you interact with the AI (e.g., chat or emotional prompts), your text input is temporarily processed by AI models to generate a response.
Input data is processed in real-time and may be briefly cached for technical delivery, but is not permanently stored or used to train external AI systems.
We may use aggregated, anonymized summaries to improve response quality and user experience, without linking data to identifiable individuals.
B. No Model Training on Personal Data
Your conversations are not used to train third-party AI models.
We adhere to a strict privacy-by-design policy: all user data remains private, secure, and separate from model learning datasets.
C. AI Ethics and Transparency
All AI interactions are designed to support wellness and emotional awareness — not to diagnose or provide medical advice.
AI responses are generated algorithmically and should not replace professional mental health care.
Users are always informed when interacting with AI features.
D. Human Review (If Any)
In rare cases where user safety or system errors require investigation, anonymized logs may be reviewed by authorized personnel under confidentiality agreements.
5. Legal Bases for Processing (GDPR Compliance)
We process data only under lawful bases:
- Consent: when you agree to share or process data.
- Performance of a contract: to deliver app services.
- Legal obligation: to comply with laws or protect safety.
- Legitimate interests: to maintain app performance and integrity.
6. Data Storage & Security
All personal data is encrypted at rest (AES-256) and in transit (SSL/TLS).
We host data on secure, privacy-compliant servers in Australia or regions with equivalent protection (e.g., the EU).
Access is restricted to authorized personnel only.
We employ continuous monitoring and anonymization to protect sensitive information.
7. International Data Transfers
If data is transferred across borders, we use recognized safeguards such as:
Standard Contractual Clauses (SCCs) for GDPR compliance, or
Transfers only to countries with adequate data protection.
8. Data Retention
We retain data only as long as necessary for its purpose or to comply with legal obligations.
You can request deletion of your account or all stored data at any time (see Section 11).
9. Your Rights
Depending on your jurisdiction, you have the right to:
- Consent: when you agree to share or process data.
- Performance of a contract: to deliver app services.
- Legal obligation: to comply with laws or protect safety.
- Legitimate interests: to maintain app performance and integrity.
To exercise any rights, contact us at info@neuroana.com.
10. Children’s Privacy
Our App is not designed for users under 18 years of age without parental consent.
We do not knowingly collect personal information from minors. If we discover such data, we delete it immediately.
11. Your Privacy Controls
You can:
- Adjust privacy and AI settings within the App.
- Request data access or deletion.
- Withdraw consent for AI interaction at any time.
- Delete your account (permanent data removal).
Requests may be sent to info@neuroana.com.
12. Third-Party Services
The App may integrate third-party tools (e.g., analytics or payment processors).
These providers operate under their own privacy policies and are selected for their compliance with global privacy standards.
13. Changes to This Policy
We may update this Policy from time to time to reflect technical or legal changes.
You will be notified of material updates through the App or via email.
Continued use of the App constitutes acceptance of the revised Policy.
14. Contact Us
If you have any privacy concerns, questions, or requests:
Email: info@neuroana.com
Mail: Post Box 3310 Broadway Nedlands 6009
Registered Entity: Neuroana Pty Ltd, Australia
Users in the EU/UK may contact their local data protection authority (DPA) for unresolved concerns.