Neuromod Devices Limited – Privacy & Cookies Policy
(last revised on 1st November 2023)
WHO WE ARE
We are Neuromod Devices Limited, incorporated and registered in Ireland with company number 490260, whose registered office is at Unit J, Digital Court, The Digital Hub, Rainsford Street Dublin 8, Ireland. (hereinafter referred to as “Neuromod”, “we”, “us” or “our”, which terms shall also include our Affiliates. “Affiliates” means any entity that directly or indirectly controls, is controlled by, or is under common control with us. “Control” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity). We are a medical technology company, specialising in the design, development, manufacture and sale to individual and corporate customers of neuromodulation technologies to address unmet clinical needs in neurology (the “Business”).
Your privacy is of paramount importance to us. This privacy and cookies policy (the “Policy”) applies to the Business and the lenire.com, and neuromoddevices.com websites and any sub-domains related to such websites (the “Websites”) and services related thereto (the “Services”). This Policy is designed to protect you, our users, by informing you what Personal Data is collected, how we will use Your Personal Data, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of Your Personal Data. Your use of the Websites is subject to your agreement with this Policy.
In this Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes Personal Data as described in Data Protection Laws (as defined below). Any Personal Data that we collect from you for these purposes is hereinafter referred to together as “Your Personal Data”.
Please read the following carefully. Use of our Websites or otherwise accepting the terms of this Policy indicates that you have reviewed this Policy and have agreed to be bound by it. If you do not agree to these terms you must leave our Websites immediately. If you no longer consent to our processing of Your Personal Data, you may request that we cease such processing by contacting us – see ‘How to Contact Us’ below.
We will handle Your Personal Data in accordance with Data Protection Laws. “Data Protection Laws” means the Irish Data Protection Acts 1988 to 2018, the UK GDPR/Data Protection Act 2018, (“UK GDPR”) the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and any other applicable law or regulation relating to the processing of Personal Data and to privacy, including the E-Privacy Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011, as such legislation shall be supplemented, amended, revised or replaced from time to time and all guidance and codes of practice issued by a relevant supervisory authority, from time to time and which are applicable to us.
We are a controller (as defined in Data Protection Laws) in relation to any Personal Data, which we collect from you through your or any other user’s use of our Services. This Policy sets out the basis on which any such Personal Data will be processed by us. In some instances, we and certain Affiliates (“Participating Affiliates”) who are party to an inter-company independent controller data sharing agreement (“DSA”) may process certain Personal Data pursuant to the terms of the DSA. We and our Participating Affiliates shall be responsible, as controllers, for our own processing of the Personal Data and will fully comply with our respective obligations as controllers under Data Protection Laws in respect of the Personal Data.
You may be a data subject (as defined in Data Protection Laws) or you may be a controller in respect of the relevant Personal Data Processed by us. When you are a controller in respect of the Personal Data of other data subjects, then you must comply with all of your controller obligations under Data Protection Laws. When you are a controller, we and you act as independent controllers, unless agreed otherwise.
INFORMATION WE GATHER FROM YOU
We fully respect your right to privacy in relation to your interactions with the Services and endeavour to be transparent in our dealings with you as to what Personal Data we will collect and how we will use Your Personal Data. We only collect and use Personal Data where we are legally entitled to do so. Information in relation to Personal Data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commission (“DPC”).
We may collect Personal Data from you in the course of your use of the Websites/Services. The information that we process includes the following:
Basic Information: such as your first and last name (including prefix or title);
Contact Information: such as your billing, home and/or business postal address, email address and phone number(s);
Profile Information: including your username and password, orders made by you, your organisation, and feedback and survey responses;
Medical/Health Information: such as medical history (incl. previous medical conditions), tinnitus history (location, duration, previous tinnitus treatments, type and sound of tinnitus), tinnitus assessments (in the form of questionnaires), tinnitus severity, sleep/anxiety scores, medications, audiograms and audiological data;
Financial Information: including your VAT number, bank account or card details and bank account details for payment processing purposes;
Technical Information: such as information from your visits to our Websites or applications (including internet protocol (IP) address and login data, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer, and other technology on the devices you use to access the Websites or applications) or in relation to materials and communications we send to you electronically;
Marketing Information: including contact information collected from you for marketing purposes such as the issue of newsletters or other communications; and
Location Data: relating to you where you request that we identify your nearest clinics offering our services.
Any Other Information relating to you which you may provide to us.
We endeavour to keep Your Personal Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible.
If you are aged under 18, please get your parent/guardian’s permission before you provide Your Personal Data to us/use the Services. We will not knowingly collect, use or disclose Personal Data from a minor under the age of 18, with-out obtaining prior consent from a person with parental responsibility (e.g., a parent or guardian) through direct off-line contact. We will provide the parent with (i) notice of the specific types of Personal Data being collected from the minor, and (ii) the opportunity to object to any further collection, use, or storage of such information. We abide by laws designed to protect children.
WHY WE COLLECT / HAVE ACCESS TO YOUR PERSONAL DATA
We may collect information from you as necessary in the course of providing our Services. We may collect Your Personal Data while monitoring our technology tools and Services, including our Websites and email communications sent to and from us. We gather information about you when you provide it to us, or interact with us directly.
We may use Your Personal Data on any one or more of the following legal bases: (i) to perform a contract with you; (ii) for our legitimate business purposes in providing the Services to you (in which case, our legitimate interests will not override your fundamental privacy rights); and/or (iii) where you have given us your express consent.
We have set out below, in a table format, a description of all the ways we plan to use Your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process Your Personal Data for more than one legal basis, depending on the specific purpose(s) for which we are using Your Personal Data. Please contact us if you need details about the specific legal basis we are relying on to process Your Personal Data where more than one ground has been set out in the table below. See ‘How to Contact Us’ below.
| Purpose | Categories of data | Legal basis for processing and, where necessary, the basis of legitimate interest |
| To respond to an enquiry from you. | basic information, and contact information. | Necessary to take steps at your request prior to entering into a contract with you. |
| To register you as a customer of our Website(s). | basic information, contact information, profile information, and financial information. | Performance of a contract with you. Necessary for our legitimate interests in protecting our business from insolvent customers and fraud. |
| To process and deliver your order. | basic information, contact information, and profile information. | Performance of a contract with you. |
| To make suggestions and recommendations to you about goods or services that may be of interest to you. | basic information, contact information, profile information, and newsletter information. | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To administer and protect our business and our Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | basic information, contact information, profile information, newsletter information, and technical information | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To provide and improve our Websites, including auditing and monitoring its use, providing and improving our Services to you and managing and administering our relationship with you. | basic information, contact information, marketing information, and technical information | Necessary for our legitimate interests to provide and improve our Websites, including auditing and monitoring its use; providing and improving our Services to you; or managing and administering our relationship with you; Necessary to fulfil our legal, regulatory and risk management obligations. |
| To determine your health requirements in respect of your tinnitus condition and provide appropriate products and services to you in this context. | health or special category data such as medical history (incl. previous medical conditions), tinnitus history (location, duration, previous tinnitus treatments, type and sound of tinnitus), tinnitus assessments (in the form of questionnaires), tinnitus severity, sleep/anxiety scores, medications, audiograms and audiological data. | Consent |
| To pseudonymise Personal Data for research and analysis purposes by Neuromod and its Affiliates and/or to consolidate Personal Data into non-identifiable form (aggregated/ anonymised data) to enhance/carry out research activities and facilitate business functions. | basic information, contact information, profile information, health or special category data such as medical history (incl. previous medical conditions), tinnitus history (location, duration, previous tinnitus treatments, type and sound of tinnitus), tinnitus assessments (in the form of questionnaires), tinnitus severity, sleep/anxiety scores, medications, audiograms and audiological data. | Legitimate Interests For research purposes explicit consent for the research will be obtained where required as per Health Research Regulations 2018 however the use of special category health data for research relies on the condition of public interest in the area of public health based on Union or Member State law under Article 9(2)(j) of GDPR. |
| To provide you with a list of clinics closest to you on a map at your request. | basic information, contact information, profile information, and location data | Consent Where you opt in to us collecting such location data for the purposes of us providing you with a list of clinics which operate our services and their specific location. |
COOKIES
A cookie is a small text file that is placed on your device by a web server, which we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. Our Websites use cookies to distinguish you from other users of our Websites. This helps us to provide you with a better experience when you browse our Websites and also allows us to improve the Websites. Cookies also help us to improve our Services and to deliver many of the functions that make your browser experience more user-friendly.
We use the following types of cookies:
| Strictly necessary cookies | These cookies are required for the operation of our Websites. They include, for example, cookies that enable you to log into secure areas of our Websites, use a shopping cart or make use of e-billing services |
| Analytical or performance cookies | These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Websites when they are using it. This helps us to improve the way our Websites work, for example, by ensuring that users are finding what they are looking for easily and to see how effective and relevant advertising on our Websites is. |
| Functionality cookies | These are used to recognise you when you return to our Websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or location) and remember if we have already asked you for feedback or to complete a survey. |
| Targeting cookies | These cookies record your visit to our Websites, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. |
These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies help us to improve our Websites and to deliver many of the functions that make your browser experience more user-friendly. You may see ‘social buttons’ during your use of the Websites, including but not limited to Twitter, Facebook, LinkedIn and Instagram which enable you to share or bookmark certain web pages. These websites and social platforms have their own cookies and privacy practices, which are controlled by them.
We use Google Analytics to obtain high-level “audience measurement” data such as the referral web domain, type of operating system/browser used, date and time of visit, and other information relating to activities on our Websites to understand its usage better, analyse trends, and optimize the Website experience. To opt out of being tracked by Google Analytics across all Websites, http://tools.google.com/dlpage/gaoptout
We use Google tracking cookies to understand if you complete certain actions on our Websites after you have seen or clicked through one of our adverts served via Google. Based on the content you have engaged with on our Websites, Google delivers some targeted advertisements across other Google partner websites. For more information, visit: https://support.google.com/ads/answer/2662922?hl=en
The ‘Help Menu’ on the menu bar of 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 and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the websites of its manufacturer.
Further information about browser privacy settings, and cookies and how to disable them can be found at www.allaboutcookies.org or ico.org.uk/your-data-matters/online/cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to fully experience the interactive features of our Websites or other related websites/applications which you visit/use.
CASES WHERE WE MAY USE YOUR INFORMATION TO CONTACT YOU
We may contact you (i) for administration reasons related to the Services (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us); (ii) to provide you with information about our Services, activities or online content, including sending e-newsletters or similar correspondence and updates or responding to any contact you have made with us – see ‘How to Contact Us’ below; (iii) to invite you to participate in surveys about our Services (participation is always voluntary); and (iv) for direct marketing purposes.
YOUR RIGHTS
As a data subject, you have the following rights under Data Protection Laws and we, as controller in respect of Your Personal Data, will comply with such rights in respect of Your Personal Data. These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of Your Personal Data, please contact us (see ‘How to Contact Us’ below). We will respond to any rights that you exercise within one month of receiving your request, unless the request is particularly complex, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond).
| Right | Further Information |
| Right of Access (Article 15 GDPR) | You have the right to request a copy of Your Personal Data. Requests for Your Personal Data must be made to us (see ‘How to Contact Us’ below) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes in managing the Services. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Data requested, we may charge you a reasonable fee to account for administrative costs of doing so); or (ii) we are entitled to do so pursuant to Data Protection Laws. For security reasons, we will take reasonable steps to confirm your identity before providing you with any Personal Data we may hold about you. |
| Right of Rectification (Article 16 GDPR) | You have the right to request that we amend any inaccurate or incomplete Personal Data that we have about you. If you would like to do this, please (i) email or write to us (see ‘How to Contact Us’ below); (ii) let us have enough information to identify you (e.g. name, registration details); and (iii) let us know the information that is incorrect and what it should be replaced with. If we are required to update Your Personal Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort. It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to Contact Us’ below). |
| Right to Object (Article 21 GDPR) | You have the right to ask us to stop using Your Personal Data, and we will comply unless there is a legal basis for us to continue using it, which we will explain to you. |
| Right to Erasure (Article 17 GDPR) | You can ask us to erase Your Personal Data (i) where we do not need Your Personal Data in order to process it for the purposes set out in this Policy; (ii) if you had given us consent to process Your Personal Data, you withdraw that consent and we cannot otherwise legally process Your Personal Data; (iii) you object to our processing and we do not have any legal basis for continuing to process Your Personal Data; (iv) Your Personal Data has been processed unlawfully or have not been erased when it should have been; or (v) the Personal Data have to be erased to comply with law. We may continue to process Your Personal Data in certain circumstances in accordance with Data Protection Laws. Where you have requested the erasure of Your Personal Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it. |
| Right to Restriction of Processing (Article 18 GDPR) | You may request that we stop processing Your Personal Data temporarily if (i) you do not think that Your Personal Data is accurate (but we may start processing again once we have checked and confirmed that it is accurate); (ii) the processing is unlawful but you do not want us to erase Your Personal Data; (iii) we no longer need the Personal Data for our processing; or (iv) you have objected to processing because you believe that your interests should override the basis upon which we process Your Personal Data. If you exercise your right to restrict us from processing Your Personal Data, we will continue to process the Personal Data if: (i) you consent to such processing; (ii) the processing is necessary for the exercise or defence of legal claims; (iii) the processing is necessary for the protection of the rights of other individuals or legal persons; or (iv) the processing is necessary for public interest reasons. |
| Right to Data Portability (Article 20 GDPR) | You may ask for an electronic copy of Your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where (i) the processing is based on your consent or for the performance of a contract; and (ii) the processing is carried out by automated means. |
| Right to be informed | You have the right to clear, transparent and easily understandable information about your rights and about how we use Your Personal Data. We use this Policy to inform you of your rights. If you have any queries please let us know – see ‘How to Contact’ us below. |
| Right to Withdraw Consent | Where processing is based on your consent, you have the right to withdraw your consent at any time with future effect by contacting us. However, if you do withdraw your consent we may not be able to continue to provide some or all of the Services we offer to you. |
| Right to ask us to stop contacting you with direct marketing | We have a legitimate interest to send you electronic communications in connection with the Services and related matters (which may include but shall not be limited to newsletters, announcement of new features etc. and which may also appear on social media platforms such as Facebook, LinkedIn, Twitter or Instagram). We may also ask you for your consent to send you direct marketing from time to time. You may be able to select your preferences with respect to direct marketing when registering on our Website(s). We may also ask you different questions for different services, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please (i) click on ‘unsubscribe’ on an email; (ii) respond ‘stop’ on an SMS to a number notified to you; or (iii) send an email via ‘How to Contact Us’ below. We will provide you with information on action taken on a request to stop direct marketing - this may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of your account/the provision of the Services. |
| Rights in relation to automated decision making | You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff. Profiling may occur in relation to Your Personal Data for the purposes of targeted advertising and de-targeting you from specified advertising. This allows us to tailor our advertising to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising. These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests. |
| Right to Complain to the DPC | If you do not think that we have processed Your Personal Data in accordance with this Policy, please contact us in the first instance (see ‘How to Contact Us’ below). If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Laws. Information about how to do this is available on the DPC website at https://www.dataprotection.ie. |
WHO WE SHARE YOUR INFORMATION WITH
We will not share Your Personal Data without your consent or unless required by law (except as set out in this Policy).
We restrict access to Your Personal Data to employees, contractors, and agents who need such access in order to operate, develop, or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations. We may also share Your Personal Data with our third party suppliers who assist us in the provision of the Services.
We also share Your Personal Data with various third parties such as business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you (subject to having appropriate contracts in place with such third parties).
Personal Data collected from you may also be transferred to a third party in the event that the business or a part of it and the customer data connected with which it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat Personal Data in accordance with this Policy. If we become involved in a merger, acquisition, or any form of sale of some of all of its assets, Your Personal Data will not be transferred to any third party unless there are adequate safeguards in place with the recipient in respect of the security of Your Personal Data.
Your Personal Data may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding in Ireland or abroad.
NON-EEA PERSONAL DATA TRANSFERS
Your Personal Data may be transferred to, stored at, or accessed from a destination outside the EEA (a ‘third country’) for the purposes of us providing the Services. It may also be processed by staff operating outside the EEA who work for us, another corporate entity within our group, or any of our suppliers. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and to an acceptable EU standard. The safeguards in place with regard to the transfer of Your Personal Data to third countries shall include (but shall not be limited to) reliance by us on a decision of the European Commission confirming an adequate level of data protection in the respective third country, the entry by us into appropriate contracts with third parties incorporating standard contractual clauses approved by the European Commission where required or reliance other appropriate safeguards and the carrying out of risk assessments and adoption of supplementary and/or mitigating measures to ensure compliance with Data Protection Laws.
THIRD PARTY WEBSITES
This Policy applies to websites and services that are owned and operated by us. We do not exercise control over the sites/applications that may be linked from the Websites. You may see ‘social buttons’ during your use of the Websites, including but not limited to Twitter, Facebook, LinkedIn and Instagram which enable you to share or bookmark certain web pages. These websites and social platforms have their own cookies and privacy practices, which are controlled by them. These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Websites may enable or assist you to access content of, correspond with, and purchase goods and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of Your Personal Data. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Websites. We encourage you to carefully familiarize yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.
HOW WE PROTECT YOUR PERSONAL DATA
We do our utmost to protect user privacy through the appropriate use of security technology. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Personal Data. In particular, we consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Personal Data transmitted, stored or otherwise processed.
We restrict access to Your Personal Data to employees, contractors and agents who need to know Your Personal Data in order to operate, develop or improve the Services. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, our Websites may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Personal Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our Services may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Personal Data arising from such risks.
All information you provide to us is stored on our (or contracted third party) secure servers. Where we have given you (or where you have chosen) a password which enables you to access any part of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with any person not authorised to use the Services.
PERSONAL DATA BREACH REPORTING
We will notify serious Personal Data Breaches in respect of Your Personal Data to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay. However, it is not necessary to notify the DPC where the Personal Data Breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data Breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
We will keep a record of any Personal Data Breaches, including their effects and the remedial action taken, and will notify you of any Personal Data Breach affecting Your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Laws. We are not required to notify you of a Personal Data Breach where (i) we have implemented appropriate technical and organisational measures that render Your Personal Data unintelligible to anyone not authorised to access it, such as encryption; (ii) we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or (iii) it would involve disproportionate effort, in which case we may make a public communication instead.
RETENTION OF PERSONAL DATA
Your Personal Data will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance. This may include retaining Your Personal Data as necessary to administer your account, comply with our legal obligations, resolve disputes, enforce our agreements, support business operations, and continue to develop and improve our Services.
Where we retain information for improvement and development of the Services, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.
AMENDMENTS TO POLICY
We may change our Policy from time to time and at our sole discretion. The date of the most recent revisions will appear on the top of this Policy. If you do not agree to these changes, please do not continue to use the Websites to submit Your Personal Data. If material changes are made to the Policy, we will notify you by placing a prominent notice on our Websites or by sending you a notification in relation to this.
HOW TO CONTACT US
If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to info@neuromoddevices.com or write to us at Data Protection, Neuromod Devices Limited, Unit J, Digital Court, The Digital Hub, Rainsford Street, Dublin 8, Ireland.
We have appointed GRCI Law Limited to act as our UK representative. If you wish to exercise your rights under UKGDPR or have any queries in relation to your rights or general privacy matters, please email our representative at ukrep@grcilaw.com. Please ensure to include our company name in any correspondence you send to our representative.