California Privacy Notice (CCPA)

1. Introduction

This California Privacy Notice supplements our Privacy Policy and applies solely to California residents. This notice describes your rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and how Neurolife, operated by Adspro Digital Private Limited, collects, uses, and shares your personal information.

Terms used in this notice have the same meanings as defined in the CCPA unless otherwise stated.

2. Categories of Personal Information We Collect

We collect the following categories of personal information from California residents:

3. Sources of Personal Information

We collect personal information from the following sources:

• Directly from you: When you create an account, complete assessments, use our Services, or communicate with us
• Automatically: Through cookies, analytics tools, and device information when you use our Services
• Third-party services: Payment processors, analytics providers, and authentication services

4. Business or Commercial Purposes for Collection

We collect and use personal information for the following business or commercial purposes:

• Providing and personalizing our Services
• Processing transactions and managing subscriptions
• Communicating with you about our Services
• Improving and developing our Services
• Security, fraud prevention, and debugging
• Legal compliance and protecting rights
• Research and analytics (using de-identified data)
• Customer support and service delivery

5. Disclosure of Personal Information

5.1 Categories of Third Parties

We may disclose personal information to the following categories of third parties:

• Service Providers: Cloud hosting, data analytics, payment processing, email services
• Business Partners: Analytics and performance monitoring services
• Legal and Safety: Law enforcement, government agencies, legal counsel (when required)
• Business Transfers: Acquirers or successors in connection with mergers, acquisitions, or asset sales

5.2 Sale and Sharing of Personal Information

5.3 Sharing for Cross-Context Behavioral Advertising

We may share certain identifiers and usage data with advertising partners for analytics purposes. You have the right to opt out of this sharing.

6. Retention of Personal Information

We retain each category of personal information for as long as necessary to fulfill the purposes described in this notice and our Privacy Policy, typically:

• Account data: Duration of your account plus 90 days after deletion
• Health assessment data: Duration of your account plus 90 days after deletion
• Transaction records: 7 years for tax and accounting purposes
• Usage data: 24 months, then aggregated or deleted
• Communications: Duration of your account or as needed for support

7. Your California Privacy Rights

As a California resident, you have the following rights under the CCPA:

7.1 Right to Know

You have the right to request:

• Categories of personal information we collected about you
• Categories of sources from which we collected your personal information
• Business or commercial purpose for collecting, selling, or sharing personal information
• Categories of third parties to whom we disclose personal information
• Specific pieces of personal information we collected about you

7.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, fraud prevention, security).

7.3 Right to Correct

You have the right to request correction of inaccurate personal information we maintain about you.

7.4 Right to Opt-Out of Sale/Sharing

While we do not sell personal information, you have the right to opt out of sharing your personal information for cross-context behavioral advertising.

7.5 Right to Limit Use of Sensitive Personal Information

You have the right to limit our use of your sensitive personal information (such as health data) to only what is necessary to provide our Services.

7.6 Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your CCPA rights. We will not:

• Deny you goods or services
• Charge different prices or rates
• Provide a different level or quality of goods or services
• Suggest you may receive a different price or quality of services

8. How to Exercise Your Rights

8.1 Submitting Requests

To exercise your rights under the CCPA, you may:

• Email: support@neurolife.fit with subject line "California Privacy Request"
• In-App: Through your account settings privacy section
• Phone: Contact our support team (if phone support is available)

8.2 Verification Process

To protect your privacy and security, we will verify your identity before processing your request. We may:

• Ask you to confirm information we have on file
• Request additional identification documents
• Use authentication methods like email verification

8.3 Authorized Agents

You may designate an authorized agent to make requests on your behalf. To do so, you must:

• Provide written authorization signed by you
• Verify your identity directly with us
• Provide proof of the agent's authority

8.4 Response Timeline

We will respond to verifiable requests within:

• 45 days of receipt
• May extend by additional 45 days with notice if necessary
• Will notify you if we cannot fulfill your request and explain why

9. Opt-Out Preference Signals

We recognize and process opt-out preference signals sent by browsers and devices, such as Global Privacy Control (GPC). When we detect such a signal from your browser, we will treat it as a valid request to opt out of the sharing of your personal information for cross-context behavioral advertising.

10. Financial Incentives

We do not offer financial incentives or price or service differences in exchange for the retention, sale, or sharing of your personal information.

11. California Shine the Light Law

Under California Civil Code Section 1798.83 (the "Shine the Light" law), California residents may request information about our disclosure of personal information to third parties for direct marketing purposes.

We do not share personal information with third parties for their direct marketing purposes without your consent. If you have questions, please contact us at support@neurolife.fit.

12. California Minors

Under California Business and Professions Code Section 22581, California residents under age 18 who are registered users may request removal of content they posted. However, our Services are not directed to individuals under 18, and we do not knowingly collect information from minors.

13. Data Collection and Use in the Past 12 Months

In the past 12 months, we have:

• Collected: The categories of personal information listed in Section 2
• Used: Personal information for the business purposes described in Section 4
• Disclosed: Categories A, B, D, E, F, and K to service providers for business purposes
• Not Sold: Any personal information
• Shared: Categories A, E, and F with advertising partners (opt-out available)

14. Changes to This Notice

We may update this California Privacy Notice to reflect changes in our practices or applicable law. Material changes will be communicated through:

• Email notification to California residents
• Prominent notice on our website
• Update of the "Last Updated" date

15. Contact Information

For questions about this California Privacy Notice or to exercise your rights, please contact us: