Privacy Policy
Last Updated: June 18, 2024
This Privacy Policy describes how NeuroTechnology Investors, LLC, NeuroTechnology Partners Fund, LLC and our subsidiaries and affiliated companies (collectively, “NTI,” “we,” or “us”) collect, use, disclose and otherwise process information about you. This Privacy Policy applies to information we collect when you access or use our websites (collectively, the “Website”), or when you otherwise interact with us, such as through our customer support channels.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
CONTENTS
Information You Provide to Us
We collect information directly from you when you create an account, request customer support, fill out a form, use our Website, or otherwise communicate with us. The categories of information we collect may include:
- Identifiers: we collect your name, email address, mailing address, and phone number. We also generate an identifier that we associate with your account.
- Communication Information: we collect information included in your communications with us.
We may also collect any other information you choose to provide.
Information We Collect Automatically
We automatically collect information about how you access our Website, which may include data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. We may also collect information about your activity on our Website and interaction with our communications, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Website.
Information We Collect from Other Sources
We may also obtain information from other sources. For example, we may collect information from identity verification services, data analytics providers, and mailing list providers. This information includes your name and contact information. We may also collect information you share when you interact with us on social media platforms like LinkedIn.
Derived Information
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.
We may use the categories of information we collect for the following business and commercial purposes:
- Website Delivery: we use information to provide and maintain our Website.
- Communication: we use information to communicate with you about NTI and our products and services, including to send you newsletters/updates, respond to your questions, and send you other transactional or relationship messages.
- Marketing and Advertising: we use information to send direct marketing messages (including via email). You can opt out of direct marketing messages we send by following the instructions in those communications (such as by clicking “unsubscribe” in the emails or by contacting us.
- Research and Development: we use information to monitor and analyze Website trends, usage, and activities, improve our Website, and develop new products and services. We may also generate de-identified data.
- Protection and Compliance: we use information to detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, help protect the rights and property of NTI and others, and comply with our legal and financial obligations.
- Notice/Consent: we may also use information in other circumstances after giving you notice and/or getting your consent.
We disclose the categories of information described above as follows:
- Vendors: we may disclose information to vendors, service providers, contractors and consultants that need this information to provide services to us, such as companies that assist us with web hosting, fraud prevention, customer service, data enrichment, analytics, and marketing and advertising.
- Marketing and Advertising Partners: we may disclose information to third parties for the Marketing and Advertising purposes described above.
- Professional Advisors: we may disclose information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- Legal Authorities and Others Involved in Legal Proceeding: we may disclose information to legal authorities and others for the Protection and Compliance purposes described above, including if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements and if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of NTI, our users, the public, or others.
- Corporate Transactions: we reserve the right to disclose information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Affiliates: we reserve the right to disclose information between and among NTI and any current or future parents, affiliates, subsidiaries, and other companies under common control and ownership.
- Consent: we may disclose information when we have your consent or you direct us to do so.
We also disclose de-identified information that cannot reasonably be used to identify you.
INDIVIDUALS IN EUROPE
Legal Basis for Processing
When we process your personal information as described above, we do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., Website Delivery).
- When we have a legitimate interest in processing your personal information to operate our business or protect our interests (e.g., Communication and Research and Development).
- To comply with our legal obligations (e.g., Protection and Compliance).
- When we have your consent to do so (e.g., Marketing and Advertising). When consent is the legal basis for our processing your personal information, you may withdraw such consent at any time.
Data Subject Requests
You have the right to request access to or deletion or correction of your personal information. In addition, you have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please contact us.
If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
Data Transfers
We may transfer personal information from the EEA, the United Kingdom, or Switzerland to non-adequate countries like the United States. We rely on appropriate safeguards such as the standard contractual clauses (“SCCs”) to do so, and you may obtain a copy of the SCCs by contacting us.
Data Retention
We may store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.
CONTACT US
If you have any questions about this Privacy Policy, please contact us.