Privacy Policy

About this policy

Neuro Pty Ltd (trading as “Neuro”) is committed to protecting and respecting your privacy. This policy describes how we collect, use and otherwise process personal information relating to you or that you provide to us:

1. When you visit or use:
   • our platform via neuroecosystem.com or one of our sub-ecosystem domains or at neuro.eco (the “Platform”);
   • any of our computer or mobile software applications (the “Apps”);
   • our social media pages;
2. when you contact us, including by email or telephone;
3. through sales and marketing activities;

Personal information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read this policy carefully to understand our practices regarding personal information.

By visiting the Platform, using the Services and/or accessing or interacting with our social media pages, you are accepting the practices described in this policy.

For the purposes of this policy, all references to the Platform shall include a reference to the Apps, and references to “Neuro”, “we”, “us” or “our” are to Neuro Pty Ltd (please see paragraph 11 entitled “contacting us” for further information).

For the purposes of data protection laws, the data controller is Neuro Pty Ltd. In this Policy, the terms “personal data (or information)”, “processing”, “data controller” and “data processor” shall have the meaning ascribed to them in the Australian Privacy Act.

What personal data do we collect?

The type of information we collect from you will depend upon the type of interaction you have with us.

Broadly speaking, the types of personal data that we collect may include:

• your first and last name, email address, salutation and information about our interactions with you and the transactions which you conduct using the Platform and/or the Services;
• personal data that you provide by completing forms on the Platform, including if you sign up to receive our newsletter, search for a product, place an order on the Platform, request any information, or enter into any competition or promotion;
• if you register or create an account with us, your log-in and password details;
• information contained in messages when you post on our social media pages;
• information contained in communications you send to us. For example when you report a problem or submit queries, concerns or comments regarding the Platform or our Services;
• data from rating and feedback systems and polls or surveys that we may, from time to time, run for research purposes or to maintain ecosystem health, if you choose to respond to, or participate in, them;

If you choose to withhold requested information, you may not be able to access all of the Platform’s content and features and we may not be able to provide our Services to you.

Website Navigational Information

We collect personal data automatically when you use the Platform and when you navigate the Platform. Data collected automatically may include information about your computer and your visits to the Platform, such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed, and other data collected through cookies and other tracking technologies. For more information on our use of these technologies, see below:

Our sites will use cookies for the following reasons:

• to provide essential features and functionality on our website;
• to ensure you are properly logged in where this is necessary to use the site;
• to store personal registration information so that you do not have to provide it to us again on subsequent visits;
• to track your progress through our site so we can make improvements to the service we offer you; and/or;
• to track visitor information and to learn about the behavior of visitors to our website, how they respond to our marketing communications and for research and statistical purposes;
• to monitor and analyze website usage and performance so that we can improve how it operates (including in relation to security) and the product selection and services available through it; and/or
• to remember any preferences which our site may allow you to set.

Cookies may be required to allow you to access and participate in certain areas of our sites.

Managing your cookies
You can manage/delete cookies as you wish – for details, see aboutcookies.org.

Removing cookies from your device
You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Be aware though that you may also lose some saved information (e.g. saved login details, site preferences).

Managing site specific cookies
For more detailed control over site-specific cookies, check the privacy and cookie settings in your preferred browser.

Blocking cookies
You can set most modern browsers to prevent any cookies being placed on your device. However, you may then have to manually adjust some preferences every time you visit a site/page and certain services and functionalities may not work at all (e.g. profile logging-in).

How do we use personal data?

We use personal data relating to you that we collect, or that you provide to us, for the purposes of our legitimate interests and/or to perform our contract as follows:

• to respond to your queries;
• to provide you with information, products or services that you request from us;
• to provide you with information, products or services that we feel may interest you (including products or services of carefully-selected, values-aligned third parties) where you have expressly consented to be contacted for such purposes (please see paragraph 14 entitled “Your rights” for further information);
• to ensure that content from the Platform is presented optimally for you and for your computer;
• to notify you about changes to the Platform and our Services;
• as part of our efforts to keep the Platform and our Services safe and secure;
• to protect our business and to enforce our rights;

How do we share personal data with third parties?

We may disclose personal data relating to you to third parties in certain circumstances including (but not limited to) the following:

• other third parties that we engage to help us run our business, such as payment processors and IT services suppliers (this includes other companies within our group who assist us to provide our Services to you);
• analytics and search engine service providers that assist us in the improvement and optimisation of the Platform;
• our professional advisors, including lawyers, accountants, tax advisors and auditors;
• law enforcement bodies, agencies, courts of law or as otherwise required or authorised by law or regulation;
• any person to whom information is required to be disclosed in connection with any litigation, arbitration, administrative or other investigation or proceedings;
• regulatory or government bodies for the purposes of resolving complaints or disputes, both internal and external, or to comply with any investigation by one of those bodies.

Where we provide supply chain finance or barter services, we may disclose personal data relating to you.

We may also disclose personal data to third parties:

• in the event that we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets and their advisors;
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• if we restructure our business, or if we integrate our business with another group of companies, in which case personal data held by us will be disclosed to the new owner to be used in the same ways set out in this policy;
• if we seek investment, in which case personal data held by us may be disclosed to investors and potential investors and their advisors;
• if we are under a duty to disclose or share personal data relating to you in order to comply with any legal or regulatory obligation, or in order to enforce or apply our Terms & Conditions on which we supply services to you; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• for any other purposes that you would reasonably expect.

Before Neuro discloses any personal data to a third party, we take steps to ensure that the third party will protect personal data in accordance with applicable privacy laws and in a manner consistent with this policy. Third parties are required to restrict their use of this information to the purpose for which the information was provided.

Although the Platform only looks to include quality, safe and relevant external links users should always adopt a policy of caution before clicking any external web links mentioned throughout the Platform.

The Platform may, from time to time, contain links to and from the websites of our distributors, partners, partner networks, sponsors, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Communication, engagement and actions taken through external social media platforms that we participate on are subject to the terms and conditions, as well as the privacy policies, of those social media platforms.

The personal data that we collect from you may be transferred to, and stored at, locations outside Australia. It may also be processed by staff operating outside the Australia who work for Neuro or for one of our suppliers or service providers.

Countries where personal data relating to you may be stored and/or processed, or where recipients of personal data relating to you may be located, may have data protection laws which differ from the data protection laws in your country of residence.

By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We will take all appropriate steps to ensure that your data is treated securely and in accordance with this policy.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect personal data relating to you, we cannot guarantee the security of such data and any transmission is at your own risk. Once we have received personal data relating to you, we use strict procedures and security features to try to prevent unauthorised access.

All information you provide to Neuro is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology. The safety and security of your information and any personal data relating to you also depends on you. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform and/or the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Neuro takes steps to destroy or de-identify personal data information that is no longer required for any purpose for which it may be used or disclosed by us and that we are no longer required by law to retain.

You have the right to access personal data held relating to you. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. You will not have to pay a fee to access personal information relating to you (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We also want to make sure that personal data relating to you that we hold is accurate and up to date. You may ask us to correct or remove any information you think is inaccurate.

You also have the right, in certain circumstances, to:

• the erasure of personal data relating to you that we hold;
• the restriction of processing of personal data relating to you that we hold;
• object to our processing of personal data relating to you that we hold;
• the portability of personal data relating to you that we hold.

Requests in this section should be sent by email or by writing to us using the contact details set out at the end of this policy.

We will only send you marketing material if you consent. When you have consented to marketing material, you have the right at any time to ask us not to process personal data relating to you for marketing purposes. You can exercise your right to prevent such processing by unchecking certain boxes or unsubscribing on the marketing emails we send you. You can also exercise the right at any time by sending an email or by writing to us using the contact details set out at the end of this policy.

If you have a concern about the way we are collecting or using your personal information, we request that you raise your concern with us in the first instance at privacy@neuroecosystem.com.

Neuro reviews and amends its privacy policy from time to time. Any changes we make to this policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check this page occasionally to review any updates or changes to this Policy. This helps you remain informed of what information we collect, how we use it and under what circumstances, if any, it is disclosed.