Neurofrog is committed to ensuring the security and protection of personal data, following the requirements of Vietnam’s General Data Protection Regulation, Decree 13/2023/ND-CP, New Zealand’s Privacy Act 2020, the EU General Data Protection Regulation, and other regulations.

Introduction

Neurofrog Ltd (we, us, our) complies with the New Zealand Privacy Act 2020 (the Act), the requirements of Vietnam’s General Data Protection Regulation, Decree 13/2023/ND-CP, New Zealand’s Privacy Act 2020, the EU General Data Protection Regulation, and other regulations, when dealing with personal information.  Personal information is information about an identifiable individual (a natural person).

This policy sets out how we will collect, use, disclose and protect your personal information.

This policy does not limit or exclude any of your rights under the Act.  If you wish to seek further information on the Act, see www.privacy.org.nz.

Changes to this policy

We may change this policy by uploading a revised policy onto the website.  The change will apply from the date that we upload the revised policy.

This policy was last updated on 11^th October 2024.

Who do we collect your personal information from

We collect personal information about you from:

• you, when you provide that personal information to us, including via the website or App and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products
• third parties where you have authorised this or the information is publicly available.

If possible, we will collect personal information from you directly.  

How we use your personal information

We will use your personal information:

• To verify your identity if required
• To provide services and products to you
• To provide customer care, communications, and support
• To improve the services and products that we provide to you
• To market our services and products to you, including contacting you electronically (e.g. by text or email for this purpose)
• To monitor the usage of the Service
• To detect, prevent and address technical issues
• To conduct research and statistical analysis (on an anonymised basis)
• To protect and/or enforce our legal rights and interests, including defending any claim

for any other purpose authorised by you or the Act.

Disclosing your personal information

We may disclose your personal information to:

• another company within our group
• any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products
• other third parties (for anonymised statistical information)
• a person who can require us to supply your personal information (e.g. a regulatory authority)
• any other person authorised by the Act or another law (e.g. a law enforcement agency)
• any other person authorised by you.

A business that supports our services and products may be located outside New Zealand or Vietnam.  This may mean your personal information is held and processed outside New Zealand or Vietnam. 

Protecting your personal information

We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse.

Accessing and correcting your personal information

Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information.  Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction.  If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

If you want to exercise either of the above rights, email us at leap@neurofrog.com.  Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).

We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information. 

How to Delete Your Account in our Mobile App

Here is a step-by-step guide on how to delete an account in our mobile app:

1. Open Neurofrog’s mobile app on your device.
2. In the app’s main navigation menu at the bottom, tap on Settings which is represented by a Cog icon  to access the app’s settings.
3. Within Settings, you will see “Delete Account”.
4. Tap on the “Delete Account”.
5. Our app will ask you to confirm your decision to delete your account.
6. Tap on the “Yes” button to proceed with account deletion or tap on the “No” or “Cancel” button if you have changed your mind and want to keep your account.
7. Once you tap “Yes” to confirm, your account has been successfully scheduled for deletion and you are logged out and taken back to the login signup screen
8. Our app will display a final confirmation message, informing you that your account has been successfully scheduled for deletion. You will also receive email confirmation of account deletion. If you do not receive an email confirmation please check your spam folder.
9. When you choose to delete your account, Neurofrog commits to permanently removing all personal data associated with your account from our databases. We prioritise your privacy and adhere to rigorous privacy and security standards. This policy is in compliance with our internal Privacy and Security Requirements, Vietnam’s Decree 13, and the General Data Protection Regulation (GDPR) mandates.

Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you follow a link on our website or App to another site, the owner of that site will have its own privacy policy relating to your personal information.  We suggest you review that site’s or App’s privacy policy before you provide personal information.

We may use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website.  You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.

Contacting us

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us at:  leap@neurofrog.com