Privacy Policy
Last Updated: September 25, 2025
We care about your privacy, and we want you to feel comfortable using the My NeurOptimal® Companion app. This policy explains what information we collect, why we collect it, and how you can control it.
Section 1. What We Collect and Why
When you use the app, we ask for:
- Your name, email address, and a password (required). This creates your account so you can log in and use the app.
- Technical information such as device identifiers, login timestamps, app usage preferences, and language settings
- Optional self-tracking inputs such as:
- Notes or personal reflections about your NeurOptimal® Sessions
- Watchlist items you choose to track (areas of life you'd like to see changes in)
- Ratings you assign to those items (such as frequency, duration, or intensity)
- Mood entries and related reflections
Entries you make in the app are for your own reflection only. Zengar® does not interpret or use this information to provide health advice, diagnoses, or treatments.
This information is requested to help the app work as intended and to let you observe your journey over time. None of these inputs are mandatory; you can use the app with only your account details, but the more you enter, the more insights the app can provide to you.
We process your account information (name, email, password) to provide the service you request, which is necessary for the performance of our contract with you (GDPR Art. 6(1)(b)). Optional self-tracking data (notes, watchlist, ratings, moods) is processed only with your consent, and you can withdraw that consent at any time by deleting your entries, deleting your account, or uninstalling the app.
Important: The app is a self-tracking tool only. Zengar® does not provide medical, therapeutic, or diagnostic services through this app, and information you enter is not reviewed or interpreted by us for any medical purpose.
1a. Categories of Personal Information We Collect (CCPA Requirement)
If you choose to enter information that could be considered health-related, we process it only as optional self-tracking content for your personal use, not as health data and not for medical, therapeutic, or diagnostic purposes.
We have never sold or shared personal information for advertising purposes, and we do not allow third parties to use your data for their own benefit.
Section 2. What We Don't Do
We do not:
- Sell your information
- Share it with marketers or advertisers
- Use it to track you
- Use it for anything outside of the app's core features
We have never sold or shared personal information, and we will not do so. Your data is yours, and we treat it that way.
Section 3. Where Your Data Lives
The information you enter is saved securely in the cloud, not just on your device. This makes sure your data is backed up if you get a new phone or reinstall the app.
Your data is encrypted while it is being sent to us ("in transit"). Once stored, it is protected on trusted servers that follow industry-standard security practices. Some data may not be encrypted at rest, but it is safeguarded by strict access controls, IP allowlists, private networking, MFA, and audited least-privilege access so that only authorized team members can access it when necessary. We also apply organizational and technical measures to keep your information safe. These safeguards and practices are designed to meet the requirements of applicable data protection laws, including the GDPR (EU/UK), CCPA/CPRA (California), PIPEDA (Canada), and Quebec's Law 25, as well as similar laws in other regions where we operate.
If you live in the European Union or United Kingdom: your data may be stored on servers in the United States. We rely on commonly accepted legal safeguards (such as Standard Contractual Clauses) for these international transfers. However, U.S. laws may not always provide the same level of data protection as in your home country.
While no online system can be 100% secure, we take ongoing steps to protect your information and reduce risks. Under GDPR and CCPA, you have rights to access, correct, or request deletion of your data, and you can contact us at any time with questions.
Section 4. App Crashes and Bugs
If the app crashes or something goes wrong, we use a trusted third-party crash reporting service to understand what happened. This helps us identify problems and improve the app. These reports do not contain information that directly identifies you. Instead, they only include technical details such as your device type, operating system version, and which part of the app caused the problem.
We also use additional third-party services to provide app functionality: PubNub for real-time features, MongoDB for data storage, and Firebase Analytics for app performance insights. These services process your data according to their respective privacy policies.
We process this information under our legitimate interest in maintaining and improving the app's reliability and performance (GDPR Art. 6(1)(f)). Under GDPR and CCPA, you have rights to access, correct, or request deletion of your personal data.
Section 5. App Permissions
The app may ask for permission to do things like send you reminders (via notifications). These are totally optional, and you can turn them on or off in your phone settings. We won't use any permissions to collect personal data.
Section 6. How Long We Keep Your Data
We keep your personal information for as long as you have an active account. If you delete your account or request deletion, we remove or anonymize your personal information from our systems within a reasonable timeframe, unless we are required to keep some of it for legal, regulatory, or security reasons.
If you would like a copy of the personal information we hold about you, please contact us at [email protected]. We will provide you with the information we are able to share in accordance with applicable data protection laws (such as GDPR and CCPA), including the rights of access, correction, deletion, and portability where applicable.
Section 7. For Parents
This app is intended for users age 16 and older. Age verification is managed through app store restrictions (Google Play Store and Apple App Store) during download. We do not knowingly collect personal information from anyone under 16.
Section 8. Your Privacy Rights
Depending on where you live (for example, in California, the EU, or the UK), you may have rights to:
- Ask us what information we have about you
- Ask for a copy of your information
- Ask us to correct your information if it is inaccurate
- Ask us to delete your information
- Ask us to receive your information in a portable format (where technically feasible)
If you would like to exercise any of these rights, you may do so from within the application, or email us at [email protected] and we will handle it manually.
Section 9. Policy Updates
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other reasons. When we make changes, we will revise the "Last Updated" date at the top of this page.
If we make material changes that affect your rights or the way we process your personal information, we will provide additional notice as required by law. This may include a notice on our website, within our services, or by email, depending on the nature of the change and the applicable legal requirements.
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
Section 10. Questions?
If you have any questions or concerns, we're here to help.
Zengar Institute Inc.
Privacy Officer: [email protected]
Website: www.neuroptimal.com
| Category of Personal Information | Examples in Our App | Purpose of Collection | Shared or Sold? |
|---|---|---|---|
| Identifiers | Name, email address, password | To create and manage your account | No |
| Personal Records | Notes or reflections you enter about your NeurOptimal® sessions; Watchlist items you choose to track; Ratings you assign (e.g., frequency, duration, intensity); Mood entries | To let you track your own progress and revisit past sessions | No |
| Internet / Technical Information | Device type, operating system, crash reports (via third-party service) | To diagnose problems and improve app performance | No |
| Inferences | None collected | N/A | No |
| Sensitive Personal Information | None collected (we do not collect financial info, health diagnoses, or government IDs) | N/A | No |
