All data collected by the Neuroom website, including personal and non-personal information, is considered confidential and is secured in accordance with the highest international security standards. We believe that your private information should remain solely at your disposal, and therefore, we strictly adhere to a privacy policy that complies with the General Data Protection Regulation (GDPR) of the European Union, as well as the norms and laws of the Russian Federation. It is important to note that this policy applies only to the use of the website neuroom.org and all its services. We guarantee that your private information is in reliable hands and will never be used for other purposes.
**Privacy Policy for Personal Data**
1. **Definitions**
This Privacy Policy (hereinafter referred to as the Privacy Policy) applies to all information that the neuroom.org website (hereinafter referred to as Da Vinci), located at the domain http://neuroom.org (as well as its subdomains), may obtain about the User during the use of the website (as well as its subdomains), its programs, and its products.
1.1 In this Privacy Policy, the following terms are used:
1.1.1. “Website Administration” (hereinafter referred to as Administration) – authorized employees responsible for managing the neuroom.org website on behalf of which they organize and/or carry out the processing of personal data, as well as determine the purposes for processing personal data, the scope of personal data subject to processing, and the actions (operations) performed with personal data.
1.1.2. “Personal Data” - any information related to an identified or identifiable individual (subject of personal data).
1.1.3. “Processing of Personal Data” - any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
1.1.4. “Confidentiality of Personal Data” - an obligation for the Operator or any other person who obtained access to personal data to prevent their dissemination without the consent of the subject of personal data or other legal grounds.
1.1.5. “Neuroom.org Website” - a collection of interrelated web pages hosted on the internet at a unique address (URL), as well as its subdomains.
1.1.6. “Subdomains” - pages or sets of pages located on third-level domains owned by the neuroom.org website, and any other temporary pages where the Administration's contact information is provided.
1.1.7. “User of the neuroom.org website” (hereinafter referred to as User) - an individual with access to the neuroom.org website via the internet who uses the information, materials, and products of the neuroom.org website.
1.1.8. “Cookies” - a small piece of data sent by a web server and stored on the user’s computer, which the web client or web browser sends back to the web server in an HTTP request each time it tries to open a page of the respective website. You can read more about Cookies here. You can set your browser to accept or block cookies independently. Inability to accept cookies may limit site functionality.
1.1.9. “Product” - a product or service that the User orders on the website and pays for through payment systems.
2. **General Provisions**
2.1. Using the neuroom.org website means the User agrees with this Privacy Policy and the terms of processing their personal data.
2.2. If the User disagrees with the terms of the Privacy Policy, they must stop using the neuroom.org website.
2.3. This Privacy Policy applies to the neuroom.org website. Da Vinci does not control and is not responsible for third-party websites that the User may access through links available on the neuroom.org website.
2.4. The Administration does not verify the accuracy of personal data provided by the User.
3. **Subject of the Privacy Policy**
3.1. This Privacy Policy establishes the Administration's obligations to maintain the confidentiality and protection of personal data provided by the User at the request of the Administration during registration on the neuroom.org website, subscribing to informational e-mail newsletters, or making a purchase.
3.2. The personal data permitted for processing under this Privacy Policy is provided by the User by filling out forms on the neuroom.org website and includes the following information:
3.2.1. Surname, name, patronymic of the User (if necessary);
3.2.2. Contact phone number of the User (if necessary);
3.2.3. Email address;
3.2.4. City, country, and postal code of the User (if necessary);
3.2.5. Company name and website of the Product (if necessary);
3.2.6. Photograph or avatar of the User (if necessary).
3.3. Da Vinci protects the data that is automatically transmitted when visiting pages:
- IP address;
- Information from cookies;
- Browser information;
- Access time;
- Referrer (address of the previous page).
3.3.1. Disabling cookies may prevent access to parts of the site requiring authorization.
3.3.2. Da Vinci collects statistics about the IP addresses of its visitors. This information is used to prevent, identify, and solve technical problems.
3.4. Any other personal information not specified above (browsing history, used browsers, operating systems, etc.) is subject to reliable storage and non-disclosure, except in cases provided in paragraphs 5.2 and 5.3 of this Privacy Policy.
4. **Purposes of Collecting User Personal Information**
4.1. The Administration may use the User’s personal data for the following purposes:
4.1.1. To identify the User registered on the neuroom.org website for their further authorization, processing of purchases, and other actions.
4.1.2. To provide the User with access to personalized data on the neuroom.org website.
4.1.3. To establish feedback with the User, including sending notifications, requests related to the use of the neuroom.org website, providing services, and processing the User's requests and applications.
4.1.4. To determine the User's location to ensure safety and prevent fraud.
4.1.5. To confirm the accuracy and completeness of personal data provided by the User.
4.1.6. To create an account for the User to access parts of the neuroom.org website, if the User consents to account creation.
4.1.7. To notify the User via email.
4.1.8. To provide the User with effective technical support in case of problems related to the use of the neuroom.org website.
4.1.9. To provide the User with special offers, pricing information, newsletters, and other information on behalf of neuroom.org with their consent.
4.1.10. To conduct advertising activities with the User's consent.
5. **Methods and Terms for Processing Personal Information**
5.1. The processing of the User’s personal data is carried out without a time limit, by any legal means, including in information systems for personal data using automation tools or without their use.
5.2. The User agrees that the Administration may transfer personal data to third parties, particularly telecommunications operators, only for the purpose of fulfilling the User's order placed on the neuroom.org website, including delivery, documentation, or email messages.
5.3. The User's personal data may be transferred to authorized state authorities only on the grounds and in accordance with the law.
5.4. In case of loss or disclosure of personal data, the Administration is entitled not to inform the User about the loss or disclosure of personal data.
5.5. The Administration takes necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, and other illegal actions by third parties.
5.6. The Administration, in cooperation with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.
6. **Rights and Obligations of the Parties**
6.1. The User has the right to:
6.1.1. Make a free decision on providing their personal data necessary for using the neuroom.org website and give consent for their processing.
6.1.2. Update or supplement the provided personal data in case of changes to such information.
6.1.3. The User has the right to obtain information from the Administration regarding the processing of their personal data unless such right is limited under federal laws. The User has the right to demand from the Administration clarification of their personal data, blocking, or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as to take necessary legal measures to protect their rights.
6.2. The Administration must:
6.2.1. Use the obtained information solely for the purposes specified in paragraph 4 of this Privacy Policy.
6.2.2. Keep confidential information secret, not disclose it without the User's prior written consent, and not sell, exchange, publish, or disclose the User's personal data in other possible ways, except as provided in paragraphs 5.2 and 5.3 of this Privacy Policy.
6.2.3. Take precautions to protect the **confidentiality of the User's personal data according to the usual practices for protecting such information in the existing business turnover.**
6.2.4. To block personal data relating to the respective User from the moment of the request or application by the User, their legal representative, or an authorized body for the protection of the rights of subjects of personal data during the verification period if inaccurate personal data or unlawful actions are identified.
7. **Liability of the Parties**
7.1. The Administration, which has not fulfilled its obligations, bears responsibility for damages incurred by the User due to the unlawful use of personal data in accordance with legislation, except in cases provided for in paragraphs 5.2, 5.3, and 7.2 of this Privacy Policy.
7.2. In the event of the loss or disclosure of Confidential Information, the Administration is not liable if this confidential information:
7.2.1. Became publicly available before its loss or disclosure.
7.2.2. Was received from a third party prior to its receipt by the Administration.
7.2.3. Was disclosed with the User’s consent.
7.3. The User bears full responsibility for compliance with legislative requirements, including advertising laws, copyright and related rights laws, trademark and service mark protection, and is fully responsible for the content and form of materials.
7.4. The User acknowledges that they are responsible for any information (including, but not limited to: data files, texts, etc.) to which they may have access as part of the neuroom.org website, and this responsibility lies with the individual who provided such information.
7.5. The User agrees that information provided to them as part of the neuroom.org website may be subject to intellectual property rights, which are protected and belong to other Users, partners, or advertisers who publish such information on the neuroom.org website. The User is not entitled to modify, lease, loan, sell, distribute, or create derivative works based on such Content (in whole or in part), except in cases where such actions have been explicitly permitted by the owners of such Content in accordance with the terms of a separate agreement.
7.6. With regard to textual materials (articles, publications) that are publicly available on the neuroom.org website, their distribution is permitted provided that a reference to the neuroom.org website is given.
7.7. The Administration is not liable to the User for any loss or damage suffered by the User as a result of the deletion, failure, or inability to save any Content and other communication data contained on the neuroom.org website or transmitted through it.
7.8. The Administration is not liable for any direct or indirect damages arising from the use or inability to use the website or individual services; unauthorized access to User communications; statements or behavior of any third party on the website.
7.9. The Administration is not responsible for any information posted by the User on the neuroom.org website, including but not limited to: information protected by copyright, without direct consent from the copyright holder.
8. **Dispute Resolution**
8.1. Prior to filing a lawsuit regarding disputes arising from relations between the User and the Administration, it is mandatory to submit a complaint (a written proposal or proposal in electronic form for voluntary dispute resolution).
8.2. The recipient of the complaint shall notify the applicant about the results of the complaint consideration in writing or electronically within 30 calendar days from the date of receipt of the complaint.
8.3. If an agreement is not reached, the dispute will be referred to the Arbitration Court of Yessentuki.
8.4. This Privacy Policy and relations between the User and the Administration are governed by the current legislation of the Russian Federation.
9. **Additional Conditions**
9.1. The Administration reserves the right to make changes to this Privacy Policy without the User's consent.
9.2. The new Privacy Policy comes into effect from the moment it is posted on the neuroom.org website unless otherwise stipulated in the new version of the Privacy Policy.
9.3. All suggestions or questions regarding this Privacy Policy should be communicated to: support@neuroom.org.
9.4. The current Privacy Policy is posted on the page at https://neuroom.org/privacy-policy.