Privacy Policy

Last updated: July 10, 2025

I. PRESENTATION

Neuromotive ("Neuromotive", "Us", "We") respects your right to privacy and understands the importance of protecting your personal data ("Data").

We adopted this privacy policy (the "Policy") to explain how we collect, process, store, share and protect the Data that you provide to Us or that we collect when you use our website ("Website"), fill out our questionnaires ("Questionnaires"), subscribe and use our application ("Application") and our wellness and productivity services (our "Services") or any other features operated by Neuromotive.

Depending on the context of the Data you provide, we may act as the data controller, joint controller, or data processor under this Policy. This Policy applies when we are acting as a controller with respect to your Data.

We reserve the right to modify the terms of this Policy at any time and in our sole discretion. If we modify the Policy, we will publish the modifications on the welcome page of the Website and/or on the home page of the Application so that you are fully informed. Any changes to the Policy will take effect thirty (30) days after its publication. Your continued use of our Services will constitute acceptance of the policy changes.

The content of this Policy is linked to our General Terms of Use, and all capitalized terms used in this Policy have the meaning given to them in the said General Terms of Use.

For your complete information, some of our current Services use artificial intelligence technology (AI). If you wish to know more about our use of AI, you can check our General Terms of Use.

Company Information:

Legal Entity: Kıvanç Uzer
Registration Number: 9010251484
Address: Fikirtepe, Kadıköy, İstanbul, 34728, Turkey
Contact: info@neuromotive.co

II. WHAT TYPE OF DATA DO WE COLLECT?

We collect your Data to provide and improve our Services. There are two general categories of Data we collect:

Data you give to Us when you:

Create and/or update your account, including your name, email address, age, payment information and any other additional information regarding your profile
Use the Services, including your productivity habits, wellness activities, task management preferences and any other additional information necessary for the use of the Service
Communicate with Us, including any content you provide to Us and any questions or requests you address to Us

You may choose not to provide certain information, but then you might not be able to take advantage of many of Our Services.

Data We automatically collect from your use of the Services:

Information about your productivity patterns and task completion rates
Information about your wellness activities and habits
Information about your performances and progress
Device and connection information, including your IP address, device type, operating system and browser type, device metrics
Information that other people provide about you when they use the Services, such as when they share tasks with you or invite you to collaborative features

Camera and Photo Library Access:

With your explicit permission, we may access:

Camera for capturing images within the app
Photo library for selecting existing images
Image metadata (date, location if available)

III. FOR WHICH PURPOSES DO WE USE YOUR DATA?

We process your Data to provide you with access and use of the Services, ameliorate your user experience and, in certain cases, comply with the law including:

To manage your account when you personalize your profile and settings
To manage your use of the Services by assisting you to achieve productivity goals, wellness programs or any other program provided by Us
To improve the Services by optimizing the usability and effectiveness of their features and functions
To provide user support by answering your requests and claims
To communicate with you about your use of the Services and any other questions or clarifications you may have
To promote Our other Services and our Partner's Services by addressing you information regarding other or upcoming Services that might be of interest to you
To prevent and detect any fraud and illegal activities to protect you and participate in investigations conducted by public authorities when required
To generate statistics regarding the use of the Services by anonymizing your data
To ensure the security of Our Services

Legal Basis for Processing:

We process your Data based on:

Consent: For marketing communications, camera/photo access, AI features
Contract Performance: Account management, service delivery
Legitimate Interests: Service improvement, security, analytics
Legal Compliance: Responding to legal requests, fraud prevention

IV. DO WE USE COOKIES OR SIMILAR TECHNOLOGIES TO COLLECT YOUR DATA?

Cookies are small text files that are automatically created by your browser and stored on your device when you connect to Our Services. We use cookies and other similar technologies for the following purposes:

To identify you when you access the Services and secure your use
To ameliorate your user experience by storing your settings and preferences
To analyze your use of the Services
To promote any of Our Services or Partner's services that might be of interest to you
To track any fraud or illegal activities

Types of Cookies:

Essential Cookies: Required for app functionality (cannot be disabled)
Analytics Cookies: Help us understand usage patterns
Preference Cookies: Remember your settings and choices
Marketing Cookies: Used for promotional purposes (with your consent)

You can manage cookie preferences through your browser settings or device settings. For more information on cookies, please refer to: http://www.allaboutcookies.org

Your cookie choices will be kept for a maximum of 6 months. Marketing-related data will be kept for a maximum of 25 months.

V. HOW WE STORE YOUR DATA

We store your Data on storage facilities located in:

European Union for European users
Turkey for Turkish users
United States of America for other users

Your Data will be stored for a period not exceeding what is necessary for the purposes for which your Data are collected and processed by Us, and in accordance with legal requirements.

Retention Periods:

Active Account Data: Duration of account activity
Inactive Account Data: 2 years after last activity
Usage Analytics: 12 months
Marketing Communications: 3 years after last interaction or until opt-out
Legal Records: As required by law (typically 5-10 years)
Camera/Photo Data: Until manually deleted by user or account termination

Your Data will be irreversibly deleted or anonymized upon termination of your use of the Services, except for data we are legally obliged to retain.

VI. DO WE TRANSFER YOUR DATA OUTSIDE THE EUROPEAN UNION OR TURKEY?

Some of our service providers and employees are located outside the European Union or Turkey. When transferring Data internationally, we ensure adequate protection through:

EU Standard Contractual Clauses
Adequacy decisions by relevant authorities
Appropriate safeguards for Turkish data subjects under KVKK

VII. HOW WE KEEP YOUR DATA SECURED?

We seek to safeguard the security of your Data and have implemented security measures consistent with accepted industry practices:

Technical Measures:

Encryption using Secure Sockets Layer (SSL) during data transport
Encryption of data at rest
Secure authentication mechanisms
Regular security assessments and penetration testing

Organizational Measures:

Physical access restrictions for our data centers
Authorization controls for data access
Employee training on data protection
Data breach response procedures

However, despite our efforts, we cannot guarantee absolute security. We urge you to take precautions to protect your Data when using the Internet or our Application.

VIII. WHICH RIGHTS DO YOU HAVE ON YOUR DATA PROCESSING?

You have the following rights regarding your Data:

Access Rights:

Request a copy of your Data we hold about you
Know how we process your Data

Correction Rights:

Rectify or update your Data through your account or by contacting us

Deletion Rights:

Request erasure of your Data (except where legally required to retain)

Restriction Rights:

Limit processing when accuracy is contested or processing is unlawful

Portability Rights:

Transfer your Data to another controller when technically possible

Objection Rights:

Object to processing based on legitimate interests
Opt-out of marketing communications
Withdraw consent at any time

For Turkish Residents (KVKK):

All rights mentioned above
Right to compensation for damages
Right to apply to the Turkish Data Protection Board

For EU Residents (GDPR):

All rights mentioned above
Right to lodge complaint with supervisory authority

For California Residents (CCPA):

Right to know categories of personal data collected
Right to delete personal data
Right to opt-out of sale (we do not sell personal data)
Right to non-discrimination

To exercise your rights, contact us at: info@neuromotive.co We will respond within 30 days of receiving your request.

IX. HOW WE MANAGE THE PROTECTION OF CHILDREN?

We are committed to protecting the privacy of children. Our Website, Application, and Services are not designed or intended for children under 18 years old.

We do not knowingly collect data from users under 18 years old
We request age confirmation during registration
For users under 18, parental consent is required
We never collect Data from children under 13 years old
Limited features may be available for users under 18

If we discover we have collected data from a child without proper consent, we will promptly delete such data.

X. WITH WHOM WE SHARE YOUR DATA?

Internal Sharing:

We share your Data with our internal teams (IT, development, marketing) to provide Services.

Service Providers:

We share Data with third-party providers for:

Cloud hosting and data storage
Payment processing
Email communications
Analytics and crash reporting
Customer support tools

We ensure service providers comply with our data protection standards.

Other Users:

When you use collaborative features or share content

Partners:

With your consent, for relevant offers and services

Legal Requirements:

To comply with law, court orders, or protect rights and safety

Business Transfers:

In case of merger, acquisition, or asset sale (with notice)

We never sell your personal data to third parties.

XI. THIRD-PARTY WEBSITE LINKS

Our Services may contain third-party links or content. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

Third-Party Advertisers:

We may use third-party advertising networks (Facebook, Google, Twitter) to promote our App. These parties may use cookies and tracking technologies. No data you share within our Application will be shared with third-party advertisers without your consent.

XII. CONTACT INFORMATION

For privacy-related questions or to exercise your rights:

Email: info@neuromotive.co
Address: Fikirtepe, Kadıköy, İstanbul, 34728, Turkey
Response Time: Within 30 days

Supervisory Authorities:

Turkey: Kişisel Verileri Koruma Kurumu (KVKK)
EU: Your local data protection authority
France: CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07

XIII. CHANGES TO THIS POLICY

July 10, 2025: Initial version published
Future updates will be listed here

This privacy policy is available in English and Turkish. In case of discrepancies, the Turkish version prevails for Turkish users.