Privacy Notice

Neuro-Technology Solutions Ltd. ("Neurotech," "us," "we," or "our") recognizes and respects the importance of maintaining your privacy and, as a result, we have established this Privacy Notice.  This Privacy Notice describes the types of information we collect from you when you visit and/or use our Site and/or Services. This Privacy Notice also explains how we may use, process, transfer, store, and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://app.axon-school.com/terms-conditions/ (the "Terms"). "You" means any Permitted Users and/or Administrator of a School and/or other permitted user utilizing the Site, and/or the Services and/or any Students participating in the Assessment and/or their parents and/or legal guardians.

Neurotech is the data controller in respect of the certain processing activities outlined in this Privacy Notice, such as processing of information related to Administrators. Our registered office is Haplada 3, Or Yehuda, Israel and our registration number is 514105287. In addition, Neurotech serves as a processor of data relating to Students, their parents and/or legal guardians, and Permitted Users on behalf of the applicable School.

"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.

Privacy Notice Key Points

The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.

• Personal Data We Collect. When you register, we collect Personal Data provided by you, such as your name, address, phone number, e-mail address, and job function. Additionally, we will collect Personal Data relating to the Students, their parents and/or legal guardians, and Permitted Users. This data may include Special Categories of Data (as such term is used in Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation)), including health data. We also (automatically) collect information about your use of the Site and Services. If you contact us for questions or complaints, we will collect the information related to your inquiry.
• How We Use the Information We Collect. We use the information (including Personal Data) we collect mainly to administer and provide the Site and Services, contact you with administrative information, and improve the Site and Services.
• Basis for Processing Your Personal Data. Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to you. Processing for the purposes of developing and enhancing new features and our products and services, for analytics and usage analysis, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
• Disclosure of Personal Data. We may share the Personal Data we collect with our service providers and subcontractors who assist us in the operation of the Site and process the information on our behalf and under our instructions. We will also share any Personal Data with the relevant School, offer the Assessment to the Student.
• International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Data. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
• Your Rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Data and obtain a copy of the Personal Data we have collected about you.
• Use of Cookies and Similar Technologies. We use cookies and similar technologies to help personalize your experience. You can adjust your settings to determine which cookies you do or do not allow. Changing your settings and/or deleting existing cookies may affect the Services.
• We retain information for as long as necessary for the purposes set forth in this Privacy Notice.
• We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Data, but they do not provide absolute information security.
• Changes to the Privacy Notice. We may change this Privacy Notice from time and shall notify you of such changes.

Personal Data We Collect

We collect information from all users who utilize the Site and/or Services.  In order to utilize our
Services, you will be required to register an account and provide us with certain Personal Data. We may also collect Personal Data when Students and/or Permitted Users utilize the Site and/or Services, when you request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.

If you are a Permitted User or Administrator, examples of the Personal Data that we collect from you may include your name, address, phone number, e-mail address, and job function. Additionally, we will collect Personal Data relating to the Students, such as their name, ID numbers, date of birth, and information related to the attentional skills of the Student or other Special Categories of Data, as well as information relating to their parents and/or legal guardians, such as name and email address. It is your voluntary decision whether to provide us with any such Personal Data, but if you refuse to provide such information we may not be able to register you to the Site, allow you to participate in the Assessment and/or provide you with the Services.

In addition to the Personal Data detailed above, certain information may be automatically gathered about your computer, mobile device, operating system, IP address, browsing history, and any data you upload in order to use the Services.  

How We Use the Information We Collect

General

We and any of our trusted third-party subcontractors and service providers may use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Site and/or Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to contact you with informational newsletters and promotional materials relating to our Site and Services; (5) to review the usage and operations of our Site and Services; (6) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (7) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services and (8) to provide customer support.

Statistical Information

In addition, by analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users ("Statistical Information"). Statistical Information helps us understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

Analytics

We, or our service providers or subcontractors, may use various tools, including "Google Analytics" to collect information about the use of the Site and/or Services ("Tools"). The Tools collect information such as how often Students and/or Permitted Users utilize the Site and/or Services. The Tools collect only the IP address assigned to you on the date you use the Site and/or Services, rather than your name or other identifying information. We do not combine the information collected through the use of the Tools with personally identifiable information. We use the information we get from the Tools only to improve our Site and Services. Google's ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use located at https://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at https://www.google.com/policies/privacy/.

Legal Uses

We may use your Personal Data as required or permitted by any applicable law.

Basis for Processing Your Personal Data

Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to you, including responding to your inquiries or requests, contacting and communicating with you and providing customer support.

Processing for the purposes of analytics and usage analysis, for fraud detection and prevention, for our record keeping and protection of our legal rights, compliance with legal and regulatory requirements, network and information security, and product development and enhancements – are all necessary for the purposes of legitimate interests that we pursue.

Disclosure of Information

We may share your information, including Personal Data, as follows:

Business Partners, Service Providers, Affiliates, and Subcontractors

We may disclose information, including Personal Data we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such information to: (1) help us provide you with the Site and/or Services; (2) aid in their understanding of how users are using our Site and Services.

International Transfer

We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them information we receive (including Personal Data). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.

Business Transfer

We may transfer our databases containing your Personal Data if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Data, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.

Law Enforcement Related Disclosure

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) to protect the rights, property or safety of third parties; (iii) when required by law, regulation subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Data as specified herein by emailing us at [email protected].

Other Uses or Transfer of Your Information

We allow you to use our Site and Services in connection with third-party services, sites, and/or mobile applications. If you use our Site and/or Services with or through such third-parties, we may receive information (including Personal Data) about you from those third parties. Please note that when you use third-parties outside of our Site and/or Services, their own terms and privacy policies will govern your use of those services.

How We Protect Information

We make efforts to follow generally-accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. The physical, electronic, and procedural safeguards we employ to protect your data are in accordance with our legal data protection requirements. For example, we have implemented Web Application Firewall, SSL encryption, database encryption and conducted penetration testing to protect your privacy. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

How to Access and Limit Our Use of Certain Information

You have certain rights in relation to the Personal Data that we or other controllers hold about you, as detailed below. For any requests to exercise such rights with respect to information held by our co-controllers, please contact the applicable controller directly. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:

• Right of Access and Data Portability. You have a right to know what Personal Data we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Data you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Data to another party. If you wish to exercise this right please contact us letting us know what information in particular you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, for instance, if the information includes Personal Data about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
• Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Data and/or that we suspend the use of Personal Data, the accuracy of which you may contest, while we verify the status of that Personal Data. We will correct your Personal Data within a reasonable time from the receipt of your written request thereof.
• Deletion of Personal Data. In certain circumstances you have a right to have Personal Data that we hold about you deleted. Should you wish to have any Personal Data about you deleted, please contact us, using the contact information specified in this Privacy Notice. Subject to applicable law, we will delete Personal Data provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Data. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should terminate your account with us and clear our cookies from any device where you have used our Services. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
• Account Deactivation. You can ask us to deactivate your account by contacting us using the information below. In order to deactivate your account, we may ask you for additional information.
• Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
• Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Data for certain purposes.
• Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.

Data Retention

Subject to applicable law and our (regulatory) obligations, we retain information as necessary for the purposes set forth above. With respect to Personal Data for which we are a controller, such data is retained for such period as you request and then will be deleted from our systems, without notice to you. With respect to Personal Data for which we are a processor, we will comply with the applicable controller's instructions with regard to retention of Personal Data. For more information, please contact the applicable controller directly.

Cookies and Similar Technologies

What are Cookies?

A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.

• A "session cookie" is temporary and will remain on your device until you leave the Site.
• A "persistent" cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it.
• First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
• Information may also be collected through web beacons, which are small graphic images ("pixel tags"), which usually work together with cookies in order to identify users and user behavior. These may be shared with third parties.

We may use the terms "cookies" to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.

How We Use Cookies

We use cookies and similar technologies for a number of reasons, for example, in order to help personalize your experience.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

How to Adjust Your Preferences

Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.

Third Party Cookies

The following third party(ies) place analytics cookies:

• Google Analytics

Communications

Subject to your consent and applicable law, we may send you in-app notifications, e-mails or other messages about us or our products and services. By accepting the terms of this Privacy Notice or using the Site and/or Services, you affirmatively consent to receive such commercial messages.  You may remove your Personal Data from our mailing list and stop receiving future communications from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at [email protected]. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send by emailing us at [email protected] Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your activities on the Site and/or Services, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may cancel your account.

Children

Students under the age of eighteen (18) who are using the Services may do so only upon the Assessment Administrator’s receipt of the relevant and required parental consent. In the event that you become aware that an individual under the age of eighteen (18) has enrolled without the necessary parental consent, please advise us immediately. 
Permitted Users and the Assessment Administrator must all be above the age of eighteen (18).

Changes and Deletion of Information

By using our Site and/or Services, you shall be asked to accept the terms of this Privacy Notice.  If you do not agree with the terms, please do not use this Site and/or the Services associated with them.  We may update this Privacy Notice from time to time, in which case we shall notify you of such changes and will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you area familiar with the latest version. Any new Privacy Notice will be effective from the date it has been accepted by you.

Comments and Questions

If you have any comments or questions about our Privacy Notice, or if you wish to exercise any of your rights, please contact us at [email protected].

Last updated: September 2018