Privacy Policy

Our mission at NeuroColor, LLC is to use the neuroscience behind personality to provide a powerful, fresh perspective on the biggest challenges facing organizations.  The customized results of our neuroscience-based personality inventory can be used to improve effectiveness, navigate critical business decisions, innovate or to better understand consumers.   To assist us in carrying out our mission, we collect and process certain information you provide us. We work hard to be good stewards of your information. This Privacy Notice is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.
What we do with the info we collect:
Anonymous and Aggregated Web Traffic Information. General traffic, site usage, browser information, length-of-stay information, and location data, is collected and stored in log files. This type of information is collected and shared on an anonymous, aggregated basis meaning that we do not connect this information to your name or other personal information.   Personal Information (non-financial). We collect all or some of the following personal information: first and family name and email address, in the following contexts:   NeuroColor Online Inventory: To participate in a NeuroColor Inventory, we require name, , and email address.  Additional demographic information is optional but requested so that we might provide the best results to you.   Client Information: If you are a NeuroColor client, we may collect business contact information which may include your personal contact information.   Requests: We collect information volunteered by users, including from requests via the Contact Form on our website.  We also may collect email addresses of those who communicate with us via email.   Online Products/Programs: We may collect some contact information you’re explicitly asked to provide in connection with certain Company products or programs.   Financial Information. We collect some payment information from clients through industry leading online third-party accounting and payment software.  We also collect payment information by phone, by check or wire transfer in connection with specific terms in your contract with NeuroColor.      Protected Health Information. NeuroColor does not collect “protected health information” as defined by the regulations issued under the Health Insurance Portability and Accountability Act (HIPAA) of 1996 via the website.    
What are Cookies and how do we use them:
We use anonymous and aggregated information to operate, develop and improve our services.   We process your personal information for the legitimate interest of enabling individuals to complete neuroscience-based personal assessments. We use these assessments to provide business solutions that increase engagement and performance for the individual, team and organization.  We evaluate your responses to our NeuroColor Surveys to create an interpretation specific to you that we provide you in an electronic file (including but not limited to a PDF format) or printed document (your “Interpretation”).  We may share some aspects of this Interpretation with your employer or sponsoring entity (“Sponsor”) if you complete a NeuroColor Survey through a Sponsor.  We also use these data results in a de-identified form to operate, develop and improve our services.   In the European Union, we have contractual relationships with consultant organizations who use our NeuroColor Survey inventories and your Interpretation to provide you and your Sponsor with business solutions for engagement and development.   Processing your information for the purposes described is necessary for us to do what we do and it’s in both of our interests.  When we use your information based on our legitimate interests, we conduct a balancing test based on the legitimate interest, necessity of processing your information, and how such processing impacts you.   We may also use or disclose your information where we conclude that we are required by law or have a good faith belief that access, preservation or disclosure of such information is reasonably necessary to protect the rights, property or safety of NeuroColor, its users or the public.   If you have any questions or concerns with us processing your information for this legitimate interest, please email us at privacy (at) neurocolor (dot) com.    We will ask for your consent before using your information for a purpose that extends beyond what you may reasonably expect from a communication guidance service provider and that has a more significant privacy impact.   NeuroColor works with trusted vendors in the following categories to help fulfill our mission and process your information for the purposes described: packaging, delivering or mailing, answering customer questions about products or services, sending postal mail, delivering consulting and storing data. We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other purpose.   As we continue to develop our business, we may buy or sell businesses or assets.  In such transactions, confidential customer information generally is one of the transferred business assets.  In the event of a transaction involving the sale of some or all of NeuroColor’s businesses, customer and site visitor information may be one of the transferred assets and may be disclosed in connection with negotiations relating to a proposed transaction.  In such case, the transferred information may become subject to a different privacy policy.  
As part of offering and providing customizable and personalized services, we use cookies and other online tracking technologies to store and sometimes track information about you to: Provide you with personalized content based on your use of our websiteEnable you to more easily use our website by remembering and using contact information and registration informationEvaluate, monitor and analyze the use of our site and its traffic patterns to help improve our website and services   The types of technologies we use include:    
A cookie is a small amount of data that is sent to your browser from a Web server and stored on your computer’s hard drive.  Cookies enable us to identify your browser as a unique user.  Cookies may involve the transmission of information from us to you and from you to us.  Cookies may also be used by another party on our behalf to transfer information to us in accordance with their privacy policy.  Some cookies are “persistent cookies.”  They are used by us each time you access our website.  Other cookies are called “session cookies.”  Session cookies are used only during a specific browsing session.  We may use a session cookie, for example, to remember that you have already navigated through a particular menu.  We may also use “analytics cookies” that allow web analytics services to recognize your browser or device and, for example, identify whether you have visited our website before, what you have previously viewed or clicked on, and how you found us.  This information is provided anonymously for statistical analysis only.  Analytics cookies are usually persistent cookies.   You may disable browser cookies in your browser or set your browser to warn you when a cookie is being sent.  You may lose some features or functionality when you disable cookies.  Remember, also, that disabling cookies is browser specific.  If you log on using Microsoft Edge, you must also disable cookies in Safari if you use that browser at a different time.   
Choices you have about your information:
You have the right to have your personal information corrected and/or erased.  You may send us an email at privacy (at)  neurocolor (dot) com to request access to, correct, or delete any personal information that you have provided to us. Please note, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.    You may have heard about “Do Not Track” (DNT), which is a privacy preference that users can set in their web browsers.  Our website does not support DNT codes. 
How we protect your information:
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those employees and contracted consultants who have a genuine business need to know it to provide you and your Sponsor with our services. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We use encryption technology for credit card numbers, bank account numbers, passwords and registration information. All client data is stored offline using our third-party cloud storage provider. All NeuroColor databases are on servers that may not be accessed by any other means than NeuroColor personnel and contractors.   We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How long we keep your information:
We keep your information only so long as we need it to provide the service you’ve requested of us and fulfill the purposes described in this policy. Because people who take NeuroColor Surveys often desire to access their Interpretation again in the future, we retain your Interpretation so that you can access it later.  In the future, we plan to use pseudonymization to further protect your Interpretation. When we no longer need to use your information for the purpose we collected it and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.
Our policy on children’s information:
If you are under 18 years of age, you may not purchase products or services from, and you should not provide information to, the website without the involvement of a parent or guardian. We do not collect online contact information without prior parental consent or parental notification, including an opportunity for the parent to prevent use of the information and participation in the activity. We do not knowingly solicit personal information online from, or market online to, children under the age of 13.
For our friends in the EU:
This Privacy Notice includes information applicable to European Union (“EU”) residents or users accessing the website in the EU. If you are an EU resident, this Privacy Notice provides you with information regarding your rights under the EU General Data Protection Regulation (“GDPR”).   Transfer of Personal Data. NeuroColor and our websites are based in the United States and, regardless of where you access the website, the information collected as part of that use will be transferred to and maintained on servers located in the United States. The European Commission has determined that the US lacks an adequate level of protection for personal information of EU data subjects. NeuroColor is not currently certified under the Privacy Shield. By logging into your NeuroColor account and clicking on “I have read this Privacy Notice” you are consenting to the transfer of your personal data to the U.S.   Although there is risk in transmitting your information to a country that the EC believes does not have adequate protection, NeuroColor does take steps to secure your personal data.   Your Choices. The GDPR provides you with certain privacy rights.  If you wish to access or update your personal information, contact us at the address or number below.  You may also request to have your information deleted, although we may retain information for backups, prevention of fraud and abuse, satisfaction of legal obligations or other ongoing legitimate interests.  You may decline to share certain personal data, in which case we may not be able to provide you with some features and benefits.   Right to Object. If you are located in the EU, you have the right to object to our processing that is based on legitimate interests by contacting us at the address or number below.    Right to Lodge a Complaint. If you are located in the EU and you believe that Company has infringed your rights under the GDPR, please contact us by sending an email to privacy (at) neurocolor (dot) com or calling us at 952.222.3230.   You have the right to lodge a complaint with a supervisory authority, in particular in your applicable Member State.
For our friends in CA:
California Civil Code Section 1798.83 permits our website visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.   California Consumer Privacy Act After January 1, 2020, you will have additional rights under the California Consumer Privacy Act of 2018 (CCPA).  If you are a resident of the State of California, you will have the right to: •          Request what personal information we have collected about you, where it was sourced from, what it is being used for, whether it is being disclosed or sold, and to whom it is being disclosed or sold; •          “opt out” of allowing us to sell your personal information to third parties; •          require us to delete your personal information with some limited exceptions such as completing transactions, detecting security incidents and complying with legal obligations; and receive equal service and pricing even if you exercise your privacy rights under the CCPA. The CCPA also provides that if a company has a privacy notice that allows you to opt-out or opt-in to the use of your personal information by third parties (such as advertisers or affiliated companies) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options. We do not currently share your personal information with third parties for marketing purposes.  Therefore, we do not maintain a list of third parties with whom we share personal information for marketing purposes.  If that changes, we will update our privacy notice. Address for California Privacy Requests Privacy (at) neurocolor (dot) com Subject Access Requests NeuroColor 14665 Galaxie Ave, Apple Valley MN 55124    
How we make changes to this policy:
We may change this policy from time to time and if we do, we’ll post any changes on this page. If you continue to use our website after those changes are in effect, you agree to the new policy. If the changes are significant, we may provide a more prominent notice or get your consent, as required by law.
Contact us:
If you have any questions about this policy or need to contact the Company to exercise your rights as a data subject under the GDPR, please contact the Company’s Privacy Officer at: privacy (at) neurocolor (dot) com or calling us at +1 952 222 3230.
Last updated September 1, 2019

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