Privacy Policy

Last updated: May 18, 2024

This Privacy Policy describes Our policies and procedures on the collection, use and
disclosure of Your information when You use the Service and tells You about Your privacy
rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You
agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions
Interpretation

The words of which the initial letter is capitalized have meanings defined under the
following conditions. The following definitions shall have the same meaning regardless of
whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of
our Service.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this
Agreement) refers to the Athlete Group International PTY LTD For the purpose of
the GDPR, the Company is the Data Controller.

Cookies are small files that are placed on Your computer, mobile device or any
other device by a website, containing the details of Your browsing history on that
website among its many uses.

Country refers to: Sydney, Australia

Data Controller, for the purposes of the GDPR (General Data Protection
Regulation), refers to the Company as the legal person which alone or jointly with
others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by AUS regulatory
authorities, for the Internet industry to develop and implement a mechanism for
allowing internet users to control the tracking of their online activities across
websites.

Facebook Fan Page is a public profile named TheNeuro-Spa.com specifically
created by the Company on the Facebook social network, accessible from https://
www.facebook.com/profile.php?id=61565690319767

Personal Data is any information that relates to an identified or identifiable individual.
For the purposes for GDPR, Personal Data means any information relating to You
such as a name, an identification number, location data, online identifier or to one or
more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on
behalf of the Company. It refers to third-party companies or individuals employed by
the Company to facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist the Company in
analyzing how the Service is used. For the purpose of the GDPR, Service Providers
are considered Data Processors.

Third-party Social Media Service refers to any website or any social network
website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of
the Service or from the Service infrastructure itself (for example, the duration of a
page visit).

Website refers to The NeuroSpa, accessible from www.theneuro spa.com You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable
information that can be used to contact or identify You. Personally identifiable information
may include, but is not limited to:

Email address

First name and last name

Phone number

Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data

Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g.
IP address), browser type, browser version, the pages of our Service that You visit, the
time and date of Your visit, the time spent on those pages, unique device identifiers and
other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use,
Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating
system, the type of mobile Internet browser You use, unique device identifiers and other
diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service
or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and
store certain information. Tracking technologies used are beacons, tags, and scripts to
collect and track information and to improve and analyze Our Service. The technologies
We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

Flash Cookies. Certain features of our Service may use local stored objects (or
Flash Cookies) to collect and store information about Your preferences or Your
activity on our Service. Flash Cookies are not managed by the same browser
settings as those used for Browser Cookies. For more information on how You can
delete Flash Cookies, please read “Where can I change the settings for disabling,
or deleting local shared objects?” available at https://www.adobe.com/au/products/
flashplayer/end-of-life-alternative.html#adobe-flash-player-eol-general-information

Web Beacons. Certain sections of our Service and our emails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel tags, and
single-pixel gifs) that permit the Company, for example, to count users who have
visited those pages or opened an email and for other related website statistics (for
example, recording the popularity of a certain section and verifying system and
server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your
personal computer or mobile device when You go offline, while Session Cookies are
deleted as soon as You close Your web browser. You can learn more about cookies
here: All About Cookies by TermsFeed.
We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available
through the Website and to enable You to use some of its features. They help to
authenticate users and prevent fraudulent use of user accounts. Without these
Cookies, the services that You have asked for cannot be provided, and We only use
these Cookies to provide You with those services.

Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available
through the Website and to enable You to use some of its features. They help to
authenticate users and prevent fraudulent use of user accounts. Without these
Cookies, the services that You have asked for cannot be provided, and We only use
these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the
Website.

Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use
the Website, such as remembering your login details or language preference. The
purpose of these Cookies is to provide You with a more personal experience and to
avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website
and how users use the Website. The information gathered via these Cookies may
directly or indirectly identify you as an individual visitor. This is because the
information collected is typically linked to a pseudonymous identifier associated with
the device you use to access the Website. We may also use these Cookies to test
new pages, features or new functionality of the Website to see how our users react
to them.

Targeting and Advertising Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies track your browsing habits to enable Us to show
advertising which is more likely to be of interest to You. These Cookies use
information about your browsing history to group You with other users who have
similar interests. Based on that information, and with Our permission, third party
advertisers can place Cookies to enable them to show adverts which We think will
be relevant to your interests while You are on third party websites.

For more information about the cookies we use and your choices regarding cookies,
please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of the
Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of
the purchase contract for the products, items or services You have purchased or of
any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent
forms of electronic communication, such as a mobile application’s push notifications
regarding updates or informative communications related to the functionalities,
products or contracted services, including the security updates, when necessary or
reasonable for their implementation.

To provide You with news, special offers and general information about other goods,
services and events which we offer that are similar to those that you have already
purchased or enquired about unless You have opted not to receive such
information.

To manage Your requests: To attend and manage Your requests to Us.

To deliver targeted advertising to You: We may use Your information to develop and
display content and advertising (and work with third-party vendors who do so)
tailored to Your interests and/or location and to measure its effectiveness.

For business transfers: We may use Your information to evaluate or conduct a
merger, divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of Our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us
about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data
analysis, identifying usage trends, determining the effectiveness of our promotional
campaigns and to evaluate and improve our Service, products, services, marketing
and your experience.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to show advertisements to
You to help support and maintain Our Service, to advertise on third party websites
to You after You visited our Service, for payment processing, to contact You.

For business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets,
financing, or acquisition of all or a portion of Our business to another company.

With Affiliates: We may share Your information with Our affiliates, in which case we
will require those affiliates to honor this Privacy Policy. Affiliates include Our parent
company and any other subsidiaries, joint venture partners or other companies that
We control or that are under common control with Us.

With business partners: We may share Your information with Our business partners
to offer You certain products, services or promotions.

With other users: when You share personal information or otherwise interact in the
public areas with other users, such information may be viewed by all users and may
be publicly distributed outside. If You interact with other users or register through a
Third-Party Social Media Service, Your contacts on the Third-Party Social Media
Service may see Your name, profile, pictures and description of Your activity.
Similarly, other users will be able to view descriptions of Your activity, communicate
with You and view Your profile.

With Your consent: We may disclose Your personal information for any other
purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the
purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the
extent necessary to comply with our legal obligations (for example, if we are required to
retain your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used to strengthen
the security or to improve the functionality of Our Service, or We are legally obligated to
retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating
offices and in any other places where the parties involved in the processing are located. It
means that this information may be transferred to — and maintained on — computers
located outside of Your state, province, country or other governmental jurisdiction where
the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information
represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated
securely and in accordance with this Privacy Policy and no transfer of Your Personal Data
will take place to an organization or a country unless there are adequate controls in place
including the security of Your data and other personal information.

Disclosure of Your Personal Data
Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may
be transferred. We will provide notice before Your Personal Data is transferred and
becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal
Data if required to do so by law or in response to valid requests by public authorities (e.g.
a court or a government agency).

Law enforcement

The Company may disclose Your Personal Data in the good faith belief that such action is
necessary to:

Comply with a legal obligation

Protect and defend the rights or property of the Company

Prevent or investigate possible wrongdoing in connection with the Service

Protect the personal safety of Users of the Service or the public

Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure. While We
strive to use commercially acceptable means to protect Your Personal Data, We cannot
guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party
vendors collect, store, use, process and transfer information about Your activity on Our
Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and
reports website traffic. Google uses the data collected to track and monitor the use
of our Service. This data is shared with other Google services. Google may use the
collected data to contextualize and personalize the ads of its own advertising
network.
You can opt-out of having made your activity on the Service available to Google
Analytics by installing the Google Analytics opt-out browser add-on. The add-on
prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing
information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google
Privacy & Terms web page: https://policies.google.com/privacy

Facebook Pixel
Their Privacy Policy can be viewed at https://www.facebook.com/policy.php

Advertising

We may use Service Providers to show advertisements to You to help support and
maintain Our Service.

Google AdSense & DoubleClick Cookie
Google, as a third party vendor, uses cookies to serve ads on our Service. Google’s
use of the DoubleClick cookie enables it and its partners to serve ads to our users
based on their visit to our Service or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for interest-based advertising
by visiting the Google Ads Settings web page: http://www.google.com/ads/
preferences/

Facebook
Their Privacy Policy can be viewed at https://www.facebook.com/policy.php

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional
materials and other information that may be of interest to You. You may opt-out of
receiving any, or all, of these communications from Us by following the unsubscribe link or
instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Email Chimp and Kajabi
Their Privacy Policy can be viewed at https://kajabi.com/policies/privacy

Payments

We may provide paid products and/or services within the Service. In that case, we may
use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI- DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Stripe
Their Privacy Policy can be viewed at https://stripe.com/us/privacy

PayPal
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/
privacy-full

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited
our Service. We and Our third-party vendors use cookies and non-cookie technologies to
help Us recognize Your Device and understand how You use our Service so that We can
improve our Service to reflect Your interests and serve You advertisements that are likely
to be of more interest to You.

Measure and analyze traffic and browsing activity on Our Service

Show advertisements for our products and/or services to You on third-party
websites or apps

Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be
impacted by browser settings that block cookies. Your browser may not permit You to block
such technologies. You can use the following third-party tools to decline the collection and
use of information for the purpose of serving You interest-based advertising: