{"id":1994,"date":"2019-08-10T13:12:04","date_gmt":"2019-08-10T13:12:04","guid":{"rendered":"http:\/\/neroes.tech\/?page_id=1994"},"modified":"2023-11-29T11:48:42","modified_gmt":"2023-11-29T11:48:42","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/neroes.tech\/pt\/privacy-policy\/","title":{"rendered":"Pol\u00edtica de Privacidade"},"content":{"rendered":"
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Privacy and Security Policy<\/h1>

This Privacy and Security Policy regulates the use of digital platforms (website and App) owned by NEROES.<\/p>

If you wish to contact Neroes regarding these digital platforms, you may do so using the following email address info@neroes.tech<\/p>

Access and use of the website and App are the sole responsibility of the User, who is subject to the acceptance of this Privacy and Security Policy and the data processing described herein. The access and use of the services provided assume that the User has read, understood and accepted the Terms and Conditions of their use, that can be consulted here<\/a>.<\/p>

Neroes reserves the right to change and review this Privacy and Security Policy at any time, as well as the data processing described herein, whenever deemed appropriate, with or without prior notice.<\/p>

This Privacy Policy constitutes an agreement between you, the User, and NEROES which applies to the use of these digital platforms. It is the sole responsibility of the user to read the Privacy and Security Policy whenever accessing the website or App, in order to be aware of any changes made, as it may affect its rights.<\/p>

1. Scope<\/h3>

This policy intends to inform about the privacy rules in the scope of the services provided by NEROES, LDA (NEROES), Portuguese tax number 515917915, with headquarters at Centro Empresarial – Zona Industrial 6060-182 Idanha-a-Nova, Portugal, also designated as Responsible Entity. The personal data you provide is treated with the security and confidentiality guarantees required by the legal framework relating to the protection of personal data.<\/p>

Any attempts to alter the information, or any other action that may cause damage and jeopardize the integrity of the system and services, are strictly prohibited under current legislation. The User undertakes to scrupulously comply with the applicable legislation, namely, in terms of computer crime and intellectual property rights, being solely responsible for the violation of these rules.<\/p>

NEROES MENTAL TRAINING PLATFORM is a computational platform (App) that allows the User to improve performance through mental training and enhancement of emotional control.<\/p>

This training makes use of the neurofeedback technique combined with a videogame that is controlled by the brain\u2019s electrical activity signals of the User. These signals are collected through a wearable electroencephalography (EEG) device that is placed over the head of the User. In addition, the App allows qualitative and quantitative assessments of the mental abilities of the User before, during and after the referred mental training, by filling out questionnaires, testing specific game\/assessments and from the signals of the brain\u2019s electrical activity themselves.<\/p>

However, it should be noted that the App is not a medical device and does not provide or can be used in order to obtain any diagnosis or mental health therapy.<\/p>

The data collected is intended for the provision of the service requested by the User, with no personal data being collected that are not necessary to provide the service or without express consent of the User.<\/p>

There are other types of information, non-personal and non-individualized, that are recorded keep website running appropriately and ensure a good browsing experience for visitors. This is statistical information that is usually by definition recorded through the browser window such as: the website address of the website that brought you directly to the neroes website, most visited website pages, type of browser, operating system, etc.<\/p>

2. What is Personal Data?<\/h3>

Personal data is information relating to a living, identified or identifiable person. Personal data can also be considered the set of different information that can lead to the identification of a specific person. Personal data that has been uncharacterized, encoded or pseudonymised, but that can be used to re-identify a person, remains personal data.<\/p>

Personal data that has been made anonymous so that the person is not or ceases to be identifiable are no longer considered personal data. For data to be truly anonymized, anonymization must be irreversible.<\/p>

Therefore, the data collected and used by the App, related to the brain\u2019s electrical activity, with questionnaires and specific tests\/assessments available on the App, are only considered personal data if associated with a living, identified or identifiable person. Otherwise, the data is not considered as personal data.<\/p>

Since the App service will use data encoding or pseudonymisation, it is necessary to obtain explicit consent for the treatment of such personal data for one or more specific purposes.<\/p>

However, the data collected is subject to irreversible anonymization and used for the overall improvement of the service provided, namely in the optimization of the algorithms used in the App, for aggregate statistical evaluation of the usage of the service, and in case the retention period ends.<\/p>

3. Typology, Purposes of Collection and Processing of Personal Data<\/h3>

3.1 Brain\u2019s electrical activity signals:<\/strong> The collection and processing of data aims to do mental training through a video game, using the neurofeedback technique, and also to evaluate and monitor the mental abilities of the User associated with the training.<\/p>

3.2 Self-reported questionnaires or reported by institutional employee: <\/strong>The requested and collected data aim to assess mental abilities associated with training, personality trait, and also the mental health state of the User. These data will be aggregated and combined with the previous data to report the current status, to monitor mental training and to optimize the training process.<\/p>

3.3 Data derived from specific tests\/games: <\/strong>The collected data reflects the performance of specific tests\/games that assesses mental abilities, which include the duration of the execution, rate of correct answers, and scores. These are intended to complement the evaluation of the mental abilities of the User, collected during the training. These data will be aggregated and combined with the previous data to report the current state of the User, monitor the mental training and to optimize the training process itself.<\/p>

3.4 Demographic data: <\/strong>The requested and collected data aim, together with the previous data, to optimize the training process.<\/p>

3.5 Contact details: <\/strong>The requested data is only intended to enable the creation of a personal and\/or institutional User account. They can also be used to contact the User for operation notifications and to obtain feedback on the service provided.<\/p>

3.6 Anonymization and aggregation of data for service optimization: <\/strong>The data collected is irreversibly anonymized and used by NEROES in an aggregated way to improve the service provided through the statistical evaluation of the usage, optimization of the algorithms or in case the retention period ends.<\/p>

4. User Profile<\/h3>

The App enables users to create individual and institutional profiles by providing explicit consent during profile creation, by accepting the checkbox related to the agreement of the Terms and Conditions. This is done prior to using the App.<\/p>

The individual User profile is intended for individuals, over 18 years old. When the user is a minor, he\/she must be accompanied by the legal guardian, both when giving consent, and when using and filling in the App data.<\/p>

The profile of the organization\/institutional User (e.g. clubs, companies), allows institutions, being responsible for the collection and processing of data of their employees and assuming the responsibilities imposed by law in terms of protection of personal data, can, in a nominal, pseudonymised or anonymized way, enter and collect the data of their employees on the App. In this profile, institutions will be able to conduct and monitor the mental training of their employees on an individual basis and still have an aggregate view of the group of employees.<\/p>

5. Entity Responsible for Data Collection and Processing<\/strong><\/h3>

NEROES, in its role as the data controller, is responsible for the collection and processing of data in strict compliance with national and community legislation in force. In fulfilling this role, NEROES ensures that:<\/p>