Neuflect, Inc.
Privacy Policy
Last updated Oct 1, 2022
Moving experiences
Neuflect, Inc. (“Neuflect,” “we,” “us,” etc.) is dedicated to improving people’s health through movement, whether that means exercise, physical therapy, athletic training, or meditative action. We do this by using technology to connect movement providers, including physical therapists, personal trainers, yoga and pilates instructors, and coaches with their clients.
Facilitating these interactions, either in person or remotely, requires that we collect personal information from everyone involved. That includes registering for our services, sharing video, or finding a professional who can help you meet your movement goals. We understand that this information needs to be collected, protected, shared, and used appropriately and we want to be transparent about our practices.
Because your personal information is valuable and sensitive, we want you to be confident that we are handling it with care and respect. We also want to give you the necessary tools and options to manage and protect that information. This Privacy Policy is part of our effort to achieve these goals.
As you interact with us, you will share your personal information in various ways. Sometimes we collect it directly from you on a voluntary basis. Other times, we use technology to automatically collect personal information. We also work with third parties with whom we share our users’ personal information.
This Policy applies to personal information collected through our FRB1 App (the App), Website (https://www.neuflect.com/), and any sites or products that display these terms (collectively, the Platform). It does not apply to any website, mobile app, service, or product that does not display or link to this Privacy Policy or that contains its own privacy notice. If you do not agree with our policies and practices, please do not use our services. By accessing the Platform or using our services, you agree to our use of information as set out in this Policy.
How we collect personal information
We may collect personal information from you directly or indirectly. When you create an account with us, for example, you provide personal information directly to us. Other times, personal information is collected automatically as you use our Platform. And in some instances, third parties with whom we work provide personal information to us.
We collect personal information when you provide it
Whether you’re a movement professional (trainer, coach, therapist), or receiving services from a movement professional, you will provide certain kinds of personal information directly by interacting with Neuflect online and offline (via the app, social media or Web forms, by phone, email, in person – or even through regular old postal mail).
When you register for an account with us, you will provide personal information that includes your name, email address, and your phone number. You will create a username and password or PIN, information that on subsequent visits helps us confirm your identity and makes it easier to use our services. When making a purchase, you will include payment information, such as credit card details to purchase our App. Along with basic identifiers, we sometimes collect demographic information, such as users’ genders, ages, and likenesses (via video or photographs). Clients also will provide personal information for their emergency contacts, in the event that someone needs urgent medical help during a session.
As movement professionals and their clients use the App, they interact directly during a session and create videos that may be shared between them or viewed later as tools to improve physical outcomes. This is true of both movement professionals (who can use them to reflect on their practice) and clients (who can use them as guides to therapy or workouts on their own). Collection, storage, and sharing of videos is always and only performed with consent and participation of both movement professionals and their clients.
We collect personal information from third-party sources
We may collect personal information about you from third parties to process purchases and payments, authenticate the identity of App users (particularly where the App user elects to authenticate through a third party like Facebook or Google), and improve our marketing efforts.
We also may collect personal information from online social networks if you use them to connect with Neuflect, or if you take part in a discussion, for example, on Instagram. We may collect personal information when you click “Share This” or “Like” buttons or otherwise use social media buttons or plug-ins.
You may decline to participate in our marketing efforts (click “Unsubscribe” at the end of our marketing emails) or not accept our cookies (through settings on your Internet browser). Keep in mind that declining certain cookies may disable some features or decrease the functionality of the App and Website.
We collect personal information using automated technologies
Sometimes personal information is collected by automated technologies and shared with us when individuals access our Platform and navigate through our products and services. We may track your browsing actions and log your IP address. We may collect data that identifies the device (phone, tablet, etc.) you are using to connect with us. We also track keystrokes, browsing histories, product preferences, and purchase histories to make future visits to our Platform more relevant and efficient.
Other automated collection technologies – such as cookies, beacons, tags, and scripts – are used by us to analyze trends, administer the Platform, and track users’ movements around the Platform. We, and our third-party partners, also use these technologies to gather demographic information about our user base as individuals and in the aggregate.
We use targeted advertising
Although we do not present ads on our Platform, we do track users’ movements to help us market our services on other websites and apps. Targeting ads on other sites in this way helps us expand our business and build awareness of services that may be relevant to you.
We will not knowingly collect information directly from individuals under age 13 without consent
Our services are not directed to anyone under age 13. However, we recognize that parents and adult caretakers may use our App to arrange for sessions between movement professionals and those under 13 years old. Parents or adult caretakers wishing to do so must consent to our use of the personal information of the individual under age 13. If we become aware that personal information of anyone younger than 13 has been provided to us without appropriate legal consent, we will delete the information from our files.
Do-not-track requests
Some browsers offer a “Do Not Track” privacy preference. Generally, when a user turns on the Do Not Track Signal, their browser sends a message to a website requesting that the user not be tracked. Our Website currently does not respond to “Do Not Track” signals.
How we use personal information
We know your personal information is important to you, so we want to be as transparent as possible while explaining how we use that information.
As mentioned above, those logging into the Platform will register by providing their names and email addresses to create profiles that include user IDs and passwords. App users may also elect to log in through third party services including Facebook, Google, etc.). Collecting this information allows easier, quicker access to our Platform on subsequent visits. As users navigate through the Platform, their movements will be tracked and analyzed. Doing so allows us to make our products better and their experiences easier.
Videos created between professionals and their clients, then shared, also improve health outcomes and make our services more worthwhile. As mentioned above, collection, storage, and sharing of videos is always and only performed with consent and participation by all parties.
We also use personal information:
To send marketing communications, typically through email.
To communicate with customers about their upcoming appointments and progress.
To respond to support requests.
To provide access to and maintain the security and integrity of the Platform.
To provide updates regarding the Platform and marketing information, such as special promotions or surveys, etc.
To comply with legal and regulatory requirements applicable to our business and internal policies for maintaining records.
To protect all parties in the event of disputes.
To comply with court orders and legal processes, and to enforce our Terms of Use and this Privacy Policy.
For any other legal, business, or marketing purposes that comply with the practices described in this Policy.
We sometimes take personal information and strip away identifying details, then combine it into collective data. This de-identified and aggregated data is then analyzed and provides us with information that allows us to predict users’ behavior, interests, and health outcomes. This not only helps us fine-tune our marketing campaigns but improve our recommendations and services.
When we share personal information
Once your personal information is collected, as detailed above, we may share it with third parties for various reasons including with our providers that host data and audio and video files, authenticate users, support our marketing efforts and assist in analyzing traffic and use of our Platform. A list of our third-party technology partners can be accessed by going here.
Note that when we share your personal information with a third party, we require that third party to protect the information consistent with this Policy and limit its use of the information to performing the services they provide to us.
If you make a public post, other users may see it
If you make a post on a third-party social media site, such as on Instagram, or by identifying us in your social media feed by tagging us using a hashtag (#) or “at” (@), your personal information may be publicly available and is subject to the privacy policies of those third-party social media sites. As a reminder, this Policy describes how we will treat your personal information once it is in our possession.
We recommend you review the privacy policies of any third-party sites you visit to understand the data collection and use practices of that third party.
We may share feedback you provide to us
We encourage our users to offer feedback on their experience with our Platform and interactions with movement professionals. Movement professionals also are welcome to reflect on their practices and share knowledge that will help their clients. Creating a community this way leads to better health outcomes for everyone. User feedback is available to anyone using the App.
We also want to hear how we’re doing. If you have suggestions for improving our Platform and its services, we want those as well. Please be aware that any feedback relating to our Platform may be publicly shared.
Eventual successors may access information
In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, any user information owned or controlled by us may be among the assets transferred to third parties as successors in interest. As part of this type of transaction, we reserve the right to transfer or assign your personal information to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred user information will be subject to this Policy.
We need to comply with legal requirements
We may disclose your information to government authorities or other third parties if any lawful circumstances arise, including when:
You have given us permission to share your information.
We are required to do so by law, or in response to a subpoena or court order.
We believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, or to protect our property or other rights or those of other users of the Platform, third parties, or the public at large.
Or we believe that you have misused the Platform by using it to attack or gain unauthorized access to a system or to engage in spamming or other conduct that violates applicable laws or our Terms of Use.
How we secure personal information
We have implemented commercially reasonable administrative, physical, and technology-based security measures to protect against loss, misuse, unauthorized access, and alteration of personal information in our systems. We ensure that any employee, contractor, corporation, organization, or vendor providing services to Neuflect and who has access to personal information in our systems is subject to legal and/or professional obligations to safeguard that personal information.
While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or form of electronic storage is 100 percent secure. Therefore, we cannot guarantee its absolute security.
Questions or concerns about security or privacy protocols.
If you have received unwanted or unsolicited e-mail from us or purporting to be sent by us, please forward a copy of that e-mail with your comments to legal@neuflect.com for our review. If you feel that any of our privacy practices or security standards detailed in this Privacy Policy have been violated, you may contact us (see Contact Us at the end of this Policy for additional details).
Your Rights
We understand that you want to protect and control your personal information. This section details how you may review, update, correct, or delete your information.
Viewing or updating your personal information
You may update your name, contact information, email preferences, physical address or other profile information by accessing your account on the Platform.
Clients are in control of videos made during their session with a movement professional; they may access, download or delete them from the Platform at any time by accessing their videos through their account on the Platform.
Deactivating your account
You may deactivate your account any time after you create it. To deactivate your account, please send an email to legal@neuflect.com with “Deactivate Account” in the subject line. Upon receiving your request, we will deactivate your account and delete personal information when allowed or required by applicable law.
Opting out of promotional emails
If you do not wish to receive promotional e-mails from us, you may follow the unsubscribe process at the bottom of the promotional e-mail you received or by emailing us at legal@neuflect.com. Please keep in mind that you still may receive transactional e-mails from us (such as e-mails related to the completion of your registration or purchases, correction of user data, password reset requests, reminder e-mails you have requested, and other similar communications) that may be necessary for us to make the Platform available to you or respond to your inquiries and support requests.
California Consumer Rights
The California Consumer Privacy Act provides specific rights to those who live in the state of California. If you are a California-based consumer, as that term is defined under California law, this section shall apply in addition to all other applicable rights and information contained in this Policy:
You have the right to request that we provide you with information about what personal information we collect, use, and disclose.
You have the right to request that we delete personal information we, or our service providers, store about you.
We will not discriminate or retaliate against you if you elect to exercise any rights under this section of our Privacy Policy.
You may request that we not sell your personal information. We do not sell, rent, lease, or trade your personal information with third parties, except as described in this Policy.
You have the right to designate an authorized agent to make a request on your behalf. Please see the Identity Verification Requirement below for information on our process for verifying we have received a legally valid request.
If you are a California consumer and have additional questions based on this section of our Privacy Policy, email us at legal@neuflect.com or complete our online form located here, select “Personal Information Request under CCPA” from the drop down list and be sure to provide the email address you used to register for an account. Be sure to check this Policy for updates, as we will review it at least every 12 months and make necessary changes.
Identity verification requirement
The law requires us to verify that any request submitted was made by someone with the legal right to access the information. Therefore, before allowing access or disclosing any information pursuant to a data subject access request, we may request that you provide us with additional information so we can verify your identity and legal authority.
To make a request, please contact us at legal@neuflect.com with “Personal Information Request” in the subject line and provide full details about your request, including your contact information and anything you believe is relevant. Alternatively, you can submit a request through our online form located here and select from the appropriate drop down options. We will provide a response to an access request within the timeframes required by law. If we cannot substantively respond in a timely manner, we will notify you and provide the reason for the delay.
Under certain circumstances, we may not fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, when we cannot verify your identity, if your request involves disproportionate cost or effort, or where the law allows us to retain that information. But we will respond to your request within a reasonable time, as required by law, and provide an explanation.
Updates
This Privacy Policy will be updated to reflect our personal information handling practices. We reserve the right to amend this Policy at any time, for any reason, without additional notice to you, other than through posting the updated Privacy Policy on our Platform. We invite you to return to this page to ensure you are informed of any updates we make about how we collect, use, and protect customer information. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the beginning of this Policy.
Contact Us
If you have questions about the way we handle personal information, please contact us:
Neuflect, Inc.
805 SW Broadway, Suite 2440, Portland, Oregon 97205