Status: May 2014
The protection of the user's personal data is a major concern of Synaptikon GmbH, a provider of NeuroNation (hereinafter referred to as "Synaptikon"). The collection, processing and use of personal data is subject to the strict requirements of the laws of the Federal Republic of Germany. These include laws of data protection, and the principle of data reduction, data transparency and data security.
The collected data will be processed and used as required for the implementation of the agreements approved by the user. The data will be processed in a way that will maintain customer relationship, legally permissible and desired by the users of Synaptikon, only in ways agreed on.
Synaptikon employs appropriate and organized security measures to protect personal data stored by NeuroNation, to prevent user's data manipulation, partial or complete loss and unauthorized access by third parties. The security measures Synaptikon employs are regulary updated as new technology develops.
The personal data will be collected with the knowledge of the user and with his or her consent when registering with NeuroNation.
According to § 3 para. 1 BDSG personal data are details of personal or material circumstances of an identified or identifiable natural person (victim).
Collection, processing and use of personal data
We do not knowingly collect any personal information from children under the age of 13. If you believe we have mistakenly collected such information, please contact us so we can resolve the issue. Where the use of a specific feature of our Google Android App requires the collection of personal data, a parental gate is presented.
Collection is the acquisition of data from stakeholders (§ 3 para. 3 BDSG).
According to § 3 para. 4 sentence 1 BDSG processing is to store, modify, transfer, blocking and deletion of personal data. The following applies in § 3 paragraph 4, sentence 2 BDSG, regardless of the procedures applied:
- Save the capture, recording or storing personal data on a disk for the purpose of further processing or use,
- Change is reshaping the content of stored personal data,
- Submit stored data obtained by data processing of personal data to a third party in such a way that:
a) the data is transferred to the third party or
b) the third party will inspect or retrieve data
- Block is identifying stored personal data in order to limit their further processing or use,
- Delete is the deletion of stored personal data.
Among benefit 3 para. 5 BDSG, any use of your personal data recorded to the extent it does not concern processing pursuant to §.
Scope and purpose of collection, processing and use of personal data
For call of NeuroNation
When you visit the online NeuroNation portal, your server is saved via NeuroNation Google Analytics.
Google Analytics is a web analytics service provided by Google Inc. ("Google"). When you visit the online portal, the data is collected and stored until an automatic deletion by Google without the intervention of the visitor in an automated procedure:
- the IP address of the requesting computer,
- the date and time of access,
- the name and URL of the file,
- the website from which the access was made,
- the operating system of the computer of the visitor, as well as the browser and other technical data used by the visitor,
- the name of the Internet access provider of the visitor,
- Language settings,
- geographical origin.
In case of activation of the IP anonymization on the website of NeuroNation, your IP address will be truncated within Member States of the European Union or other parties to the Agreement on the European Economic Area.
Only in exceptional cases will the full IP address be transferred to a Google server in the USA and is then shortened. On behalf of Synaptikon, Google will use this information to evaluate your use of the online portal, compiling reports on website activity and providing others with website usage and internet related services to Synaptikon. Undertaken as part of Google Analytics, a web browser IP address is not associated with any other data held by Google.
Thus, the user has the possibility to prevent this data collection and object at any time.
Based on the evaluations of Google Analytics, Google uses DoubleClick DART cookies and can share information about the visit of the user on the NeuroNation site and other websites in order to provide advertisements that may interest the user (interest-based ads). The information generated by the cookie regarding the use of NeuroNation, including IP address, are transmitted to and store by Google using their servers. In addition, Google may also transfer this information to third parties, when required to do so by law, or where third parties process the information on Google's behalf. Google will not use your IP address in conjunction with any other data held by Google. The information transmitted in this service does not include your name, address, email address or phone number.
If the user does not want to use DoubleClick DART cookie, the plug in can be turned off using the Ads Preferences Manager: http://www.google.com/settings/ads/onweb/?hl=en.
Register as a user of NeuroNation
During registration, the user enters the following data:
- Email address
The input of other personal data for the preparation and completion of the user's account is voluntary. However, the accurate input of these data is required for full use of Neuronation.
Other personal data requested by Synaptikon provides the user of NeuroNation personalised training; in order to identify the benchmark comparison group. In addition, data processing and administration is required to verify the data entered for plausibility and the users capacity (ie. for content design, execution and modification of the contract with the user through their use of NeuroNation, and for other inquiries).
The user's password is stored, encrypted, only in the database. The unique recovery password for the encrypted data is not accessible, either by Synaptikon or a third party.
When using NeuroNation as a registered user
Synaptikon collects the data of registered NeuroNation users for statistical purposes to enable the smooth functioning of NeuroNation to correct malfunctions, better understand the user's needs, and optimise and personalize the product. Depending on the user's request, the data can be displayed in the profile or can be accessible only to the user.
The data includes:
- Comments that have submitted to NeuroNation by the user
- the movement behaviour of the user on the online portal of NeuroNation, ie time of last login
- which pages the user has looked at on NeuroNation
Accesses are logged and analysed.
Interaction with other users (Premium account and freemium account)
If the user does not object to the comparison of his/her brain training performance to other users ("brain comparison" and "best list"), the user then consents at the time of registration with NeuroNation, that his/her scores are incorporated in the anonymized statistics calculated by Synaptikon.
The values obtained by Synaptikon are only segregated by age and gender of the user, if specified for statistical purposes, and are always stored anonymously in this context and later evaluated.
Personal data of persons with limited competence
If the user is of limited competence, and guardians do not agree with personalised data being collected, processed or used during registration and online training, we urge the parents or guardians to contact NeuroNation using the following email address:
The parents or guardians should tell us if the data should be deleted.
Synaptikon requests for verification of parental or guardian permission (ie. copy of identity card). On submission of proof, Synaptikon will then arrange for immediate deletion of the user account and data.
Disclosure of personal data to third parties
User's personal data will not be transferred to third parties, unless this is necessary for the fulfilment of contractual relationships. Authorities or other government institutions will only have access to user's personal information in accordance with statutory disclosure requiriments, or following a court's decision.
If the user only registers for the free NeuroNation deal with the Freemium account, the user then expresses his/her agreement to regularly receive emails regarding NeuroNation offers. The user can object to their consent by contacting us at firstname.lastname@example.org.
Payment service provider
Synaptikon has commissioned a reliable payment service with Novalnet AG, with settlement of payments (SEPA Direct Debit and credit card). For this purpose, the Novalnet AG requires certain information including personal information from users. These are: user's name and address, IBAN and BIC or credit card number (including validity period), as well as the invoice amount, the currency, and the transaction number. Novalnet AG may use this information for the purpose of payment and pass on to Synaptikon. It is obliged to treat the information in accordance with the German data protection laws.
If other payment service providers are selected when ordering (ie. PayPal), the necessary information will be requested.
Discovery, correction, blocking and deletion of user data (Freemium account)
If the user has a freemium account, where he/she chose to "Delete Account" on profile settings, the deletion of the account will include the deletion of all user data, including all points, ratings and comments.
If the User provides due notice when terminating their premium account, the account will be given the status of a freemium account. The data generated by the Premium account will be persevered, and can be made available if the user chooses Premium once more. As long as the user is on the Freemium account, he/she is not entitled to use of the data.
If the premium account is terminated in the case of other circumstances, no setback in the freemium account and all user data including points, ratings, and comments will be deleted.
The user may at any time request information stored by Synaptikon.
The user may request correction, blocking and the deletion of their personal data in writing or by email at any time. For these purposes, the user should contact us via:
Cookies are small data files stored on the hard disk of the user's computer and the user's web browser stores. Most of the cookies used by NeuroNation are so-called 'session cookies'. These are automatically deleted at the end of the user's visit to the online NeuroNation portal. Cookies on the user's computer are of no harm and do not contain viruses. The user can use the online NeuroNation portal without cookies however. If the user does not wish to have NeuroNation to have access to their online data visit, the user can prevent cookies from being stored on their computer's hard drive. Most computers are automatically set to accept cookies. The user can deactivate the storing of cookies or adjust their browser so it alerts the user to the sending of cookies.
Synaptikon sends registered users a monthly newsletter. This newsletter provides the user the latest NeuroNation news, as well as style and product suggestions which might please the user. Synaptikon uses the email address of the user exclusively for the transmission of the newsletter, given the user is still registered and has not requested the monthly newsletter to not to be sent to him/her.
To receive the newsletter, the user's email address must be provided when registering with a click on the confirmation link to validate (double opt-in). If the user has not ordered the newsletter during registration, the user can request subscription by contacting NeuroNation via the site's profile page or by emailing email@example.com.
The newsletter can be cancelled at any time using the link on the newsletter. Additionally, the user can write "cancel newsletter" in the subject line of an email sent to firstname.lastname@example.org.
Use of Facebook plugins
The online portal of NeuroNation uses social plugins (the "Plugins") of the social network facebook.com (herein referred to as "Facebook"). The plugins are identifiable by a Facebook logo (white "f" on blue background or a "thumbs up" sign), or marked by the addition "Facebook Social Plugin".
The list and the appearance of the Facebook social plugins can be found at the following address: http://developers.facebook.com/plugins.
When the user visits a web page of the online portal of NeuroNation containing such a plugin, the web browser of the user establishes a direct connection with the Facebook servers. The content of the plugin is from Facebook directed to the web browser of the user, and integrated into the website. Therefore, NeuroNation has no effect on the scope of the data which the Facebook plugin collects and informs the user according to his level of knowledge.
The purpose and the scope of the data collected by the Facebook plugin, as well as the rights of adjust their settings due to issues of privacy
For more information regarding the purpose, processing and scope of data collection by Facebook, and the relevant rights and ways to protect the privacy of the user, please check the privacy policies of Facebook: http://www.facebook.com/policy.php.
Synaptikon will update NeuroNation's privacy rules from time to time to protect the personal data of the user. The user should monitor the Privacy Statement to stay informed on how NeuroNation protects the user's data and improves the content of the website. If Synaptikon makes material change in the collection, use and/or disclosure of user's personal data, Synaptikon will make a clear and prominent notice on the website to alert users.
Accessibility of Privacy rules
To open this document, the Acrobat Reader from Adobe Systems Inc. is required, and can be obtained free of charge from the following address: http://www.adobe.com/downloads/.
The data protection rules may also be sent to you on request.
Please email NeuroNation at:
or write to
Synaptikon GmbH, NeuroNation,
Questions and accessibility
Should the user have any questions regarding privacy, NeuroNation can be contacted at: