Last updated: January 24, 2023.

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Neuroelectrics Barcelona S.L.U. We are committed to being transparent about the data we collect, how we use it, and with whom we share it. Any information relating to the person from which the person can be identified is known as “Personal data.” Any individual as a customer, an employee, or supplier personnel working for the company is known as a “Data subject.” NEUROELECTRICS BARCELONA, S.L.U. is the name we use to refer to our business and any of its offices. When we use the words we or our, we mean NEUROELECTRICS BARCELONA, S.L.U.

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This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

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We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Free Privacy Policy Generator.

- Interpretation: The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear singular or plural.

- Definitions. For the purposes of this Privacy Policy:

• Account: means an individual account created for You to access our Service or parts of our Service.

• Company: (referred to as either 'the Company,' 'We,' 'Us,' or 'Our' in this Agreement) refers to Neuroelectrics S.L.U, Av Tibidabo 47 bis, Barcelona.

• Cookies: are small files placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Country: refers to Spain.

• Device: means any device that can access the Service, such as a computer, a cellphone, or a digital tablet.

• Personal Data: is any information related to an identified or identifiable individual.

• Service: refers to the Website.

• Service Provider: means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.

• Usage Data: refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Data Controller: for the GDPR (General Data Protection Regulation), refers to the Company as the legal person who, alone or jointly with others, determines the purposes and means of processing Personal Data.

• Website refers to Neuroelectrics, accessible from https://neuroelectrics.com/.

• You mean the individual accessing or using the Service, the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

• Clinical Research/Clinical Trial/Study: Any investigation in human subjects intended to discover or verify the clinical, pharmacological, and/or other pharmacodynamic effects of an investigational product(s) and/or to identify any adverse reactions to an investigational product(s), and/or to study absorption, distribution, metabolism, and excretion of an investigational product(s) with the object of ascertaining its safety and/or efficacy. The terms clinical trial and clinical study are synonymous.

• Patient/Subject/Trial Subject: An individual who participates in a clinical trial, either as a recipient of the investigational product(s) or as a control.

- Types of Data Collected

Personal Data: While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include but is not limited to:

Email address:

First name and last name:

Phone number:

Address, State, Province, ZIP/Postal code, and City:

Usage Data:

Usage Data: Usage Data has collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies: we use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies are beacons, tags, and scripts to collect and track information and improve and analyze Our Service.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

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Cookies: can be 'Persistent' or 'Session' Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about Cookies in the “ “What Are Cookies.” article. We use both Sessions, and Persistent Cookies for the purposes set out below:

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Necessary / Essential Cookies:

Type: Session Cookies
Administered by: Us
Purpose: these Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies
Administered by us
Purpose: these Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: these Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time. You use the Website.

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​For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

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Web Beacons: certain sections of our Service and emails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags, and single-pixel gifs). That permits the Company, for example, to count users who have visited those pages or opened an email and other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Use of Your Personal Data: the Company may use Personal Data for the following purposes:

• To provide and maintain our Service: including monitoring the usage of our Service.

• To manage Your Account: to manage Your registration as a Service user. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You: with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

• To manage Your requests: to attend to and manage Your requests to Us.

• For business transfers: we may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: we may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing, and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may transfer Your personal information with Service Providers to monitor and analyze the use of our Service to contact You.

• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates: We may share Your information with Our affiliates, which will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us.

• With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.

• With other users: when You share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data: the Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally kept for a shorter period, except when this data is used to strengthen the security or improve our Service's functionality. We are legally obligated to retain this data for longer periods.

Transfer of Your Personal Data: your information, including Personal Data, is processed at the Company's operating offices and other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers outside your state, province, country, or other governmental jurisdiction where the data protection laws differ from yours.

Your consent to this Privacy Policy, followed by Your submission of such information, represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

Delete Your Personal Data: you have the right to delete or request that We assist in deleting the Personal Data We have collected about You.

Our Service may allow You to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information you have provided.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data:

• Business Transactions: If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

• Law enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Data if required by law or in response to valid requests by public authorities (e.g., a court or a government agency).

• Other legal requirements: The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of Users of the Service or the public, protect against legal liability.

• Security of Your Personal Data: The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data: Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

-Analytics: We may use third-party Service providers to monitor and analyze the use of our Service.

• Google AnalyticsGoogle: Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network. You can opt out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

- Email Marketing: We may use Your Personal Data to contact You with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any or all of these communications from Us by following the unsubscribe link or instructions in any email We send or by contacting Us. We may use Email Marketing Service Providers to manage and send emails to You.

With a special character and attention to the fact that the Company has as its object clinical Research studies in the field of Medical Devices. In addition to those indicated above, data protection policy also includes different regulations.

Clinical studies represent a major part of a new therapy’s overall time to market and can typically run for at least six to seven years across the industry.

When we plan and conduct clinical research, we involve Patients wherever possible throughout the process: they, as well as physicians, and other healthcare professionals, all have a voice in designing the studies. For example, Patients are consulted on the study design concept, including the clinical design with a specific emphasis on patient-relevant measurements and how educational materials can be developed to support Patients and their families.

By using this patient-led approach, we aim to achieve outcomes that will be meaningful and helpful to patients. Throughout our clinical studies, Patient safety is a priority. There are, rightly, stringent requirements regarding Patient safety in clinical studies. It is important to collect, analyze and act upon any new information about the benefits and risks of our products, whether in clinical Research is on the market.

• Confidentiality and Patient’s Personal Data Protection: To perform clinical studies and to meet the studies’ objectives, the processing of Patients’ Personal Data is required. This section provides information regarding the use of Patients’ Personal Data in Neuroelectrics studies and patients’ rights concerning Personal Data, which is required by applicable data protection laws, including the EU Regulation 2016/679, called the General Data Protection Regulation (GDPR).
   

• The legal basis for collecting and processing patients’ Personal Data for the purposes mentioned above is the consent provided by them or according to local requirements, the legitimate interest and Scientific Research in the public interest, as prescribed by EU General Data Protection Regulation 2016/679 (section 6.1 (f) and 9.2(j)).
   

• Personal Data may also be processed to comply with legal requirements related to the conduct of a clinical study, i.e., safety reporting, archiving of clinical data, and disclosure of clinical data to competent national authorities during an inspection. The legal basis for processing such Personal Data is to comply with a legal obligation. That processing is necessary for reasons of public interest in the area of public health (EU General Data Protection Regulation, “GDPR,” article 6(1)(c) and 9(2)(i)).
   

• Which Patient’s Personal Data do We process, and where do they come from? On the occasion of your relationship with us, the following categories of Patients Personal Data may be processed: identification data, contact data (including signature and image); data related to health integrated into the patient's Clinical History; personal characteristics, social circumstances; transactional data (payments, income, transfers, debits, bank account)

The data may come from the interested party or, where appropriate, from health personnel or hospitals, in which case the data received is always anonymized, without being able to relate, by own imposition of the health centers, the identification data with health data.

For what purpose do We process Patients' Personal Data?

• Scientific research: your data may be processed for scientific purposes, complying with the specific regulations in this regard.
   

• Anonymization and pseudonymization procedures: Certain procedures may be applied to your data so that they are not identifiable or cease to be, or so that they can no longer be attributed to an interested party without using additional information that appears separately, for scientific or statistical Research purposes. .
   

• Attention to requests for information, complaints, suggestions, claims, the exercise of data protection rights, etc.: in these cases, We will process your Personal Data to manage and process the request.
   

• Compliance with legal obligations: it may be necessary to process Personal Data in order to comply with the corresponding legal requirements. Specifically, to comply with the legislation on data protection, tax, health, etc.
   

• Formalization and execution of the contract: the Personal Data of the interested party are processed in order to manage the contractual relationship related to the corresponding Research project.

The Personal Data collected will be processed for the specified purposes and in no case in a manner incompatible with said purposes.

What is the legitimacy of the processing of Patient Personal Data?

• Purpose: Scientific research.

• Basis for Treatment: Consent. Compliance with a legal obligation. Processing necessary for scientific Research and/or legitimate interest of the data controller.
   

• Purpose: Anonymization and pseudonymization procedures for scientific Research or statistical purposes.

• Basis for Treatment: Consent. Compliance with a legal obligation. Processing necessary for scientific Research and/or legitimate interest of the data controller.
   

• Purpose: Attention to requests.

• Basis for Treatment: Treatment is based on the data subject's consent and/or the data controller's legitimate interest.

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• Purpose: Compliance with legal obligations.

• Basis for Treatment: Treatment is necessary for compliance with a legal obligation applicable to the data controller treatment.
   

• Purpose: Formalization and execution of the contract.

• Basis for Treatment: Treatment is necessary for the execution of a contract in which the interested party is a party.
   

• Purpose: Sending commercial communications.

• Basis for Treatment: Treatment is based on the consent of the interested.
   

How long will We keep Patients' Personal Data?

In general, Patient data will only be kept for the time strictly necessary for the purpose they were collected.

The Personal Data processed for scientific Research will be kept for the appropriate time in each case according to the type of Research study in which You participate and taking into account the applicable regulations. Regarding the data processing for Scientific Research purposes, the Control Authorities of the Autonomous Communities (Comunidades Autónomas) may, upon request of the person responsible for the treatment and in accordance with the procedure established by law, agree to the full maintenance of certain data, taking into account the historical, statistical or scientists in accordance with the legislation that applies to each case.

The Personal Data provided for the purpose of managing any request for information, complaint, suggestion, claim, the exercise of data protection rights, etc., will be kept for the time necessary to process the request and, in any case, for the time established. Legally and during the period necessary for formulating, exercising, or defense of claims.

The Personal Data processed to comply with legal obligations will be kept for the time established in the applicable legislation.

The Personal Data collected for the formalization and execution of the contract will be kept for the duration of the contractual relationship and the period necessary for the formulation, exercise, or defense of claims, at least five years.

To which recipients will your Patient's Personal Data be communicated?

In order to guarantee an adequate provision of the Service, certain Service Providers and/or group entities must process data on behalf of the person in charge and as managers of the treatment of your Personal Data. These entities can be, for example, Service Providers of medical, diagnostic, clinical analysis, auditing, physical security, archiving, storage or digitalization of information, destruction of documentation, legal advisory services, computer services, etc.

Your Personal Data will not be communicated to third parties except by legal obligation, vital interest, or prior consent of the interested party.

The data processed for scientific Research purposes may entail international data transfers; in these cases, You will be informed of this possibility as well as the guarantees so that they can be carried out, or, failing that, your consent will be requested. All the information We receive that is provided will be treated confidentially and in strict compliance with the security obligations necessary to prevent access by unauthorized third parties.

Which are Patients’ rights regarding their Personal Data?

In respect of the Personal Data that We have collected about You, You have the right, in certain circumstances, to

• Request access to this Personal Data,

• Request the correction of this Personal Data,

• Request the erasure of this Personal Data,

• Request that we restrict how we process this Personal Data,

• Object to how we process this Personal Data,

• Request a copy of the Personal Data you have provided to Neuroelectrics in an electronic format,

• You can also Withdraw your consent to the processing of your personal data at any time, but this will not affect the lawfulness of the processing before that time.

However, You must take into account that Personal Data for Health Research purposes, and in particular biomedical research, for article 89.2 of the GDPR, may be exempted from the rights of the affected parties provided for in articles 15, 16, 18, and 21 of the GDPR when:

• The rights mentioned above are exercised directly before researchers or Research centers that use anonymized or pseudonymized data.

• The exercise of such rights refers to the results of the investigation.

• The investigation has as its object an essential public interest related to State security, defense, public safety, or other important objectives of general public interest, provided that in the latter case, the exception is expressly included in a norm with the force of Law.

In the case of participating in a Research study, to exercise your rights, You can contact the Principal Investigator of the Research study in which You participate, whose contact details are on the information sheet for the participant that was previously delivered to you. to consent to participate in the study.

In addition, We inform You of the possibility of filing a claim with the competent control authority in accordance with the procedure that corresponds to the specific case.

For more information regarding the processing of Personal Data in Neuroelectric’s studies and patients’ rights concerning such processing, please contact Neuroelectric’s Data Privacy Officer at gdpr@neuroelectrics.com.

Personal Data We collect from You may be transferred to countries outside the EEA where Neuroelectrics operates. As an international organization, Neuroelectrics operates in a number of countries, including the USA. Some countries outside the EEA may not have a data protection supervisory authority, and/ or data processing principles and/ or data subject rights might not be provided for in that country. So, You might not be able to enforce your rights in the same way, and recipient organizations may not be legally required to secure your data to EU standards. Neuroelectrics shall take all necessary steps to protect your Personal Data in such circumstances.

We maintain processes to ensure that any third party We are using and who will process your data, including other Neuroelectrics entities, will comply with the same standards to protect your data as in the EEA. This includes carrying out necessary due diligence on such third parties (for example, the security measures they have in place for protecting data). Entering into contracts that contain adequate contractual measures to protect Personal Data, which can include contracting on standard contractual clauses that EU authorities have approved as providing adequate protection.

Legal Basis for Processing Personal Data under GDPR. (We may process Personal Data under the following conditions):

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task carried out in the public interest or the exercise of official authority vested in the Company.

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help clarify the specific legal basis that applies to the processing, particularly whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

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- Your Rights under the GDPR

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The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee. You can exercise Your rights.

You have the right under this Privacy Policy, and by law, if You are within the EU, to:

• Request access to Your Personal Data: The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request the deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
   

• Request correction of the Personal Data: that We hold about You. You have the right to have any incomplete or inaccurate information. We hold about You corrected.
   

• Object to processing of Your Personal Data: This right exists where We are relying on legitimate interest as the legal basis for Our processing. There is something about Your particular situation which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
   

• Request the erasure of Your Personal Data: You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
   

• Request the transfer of Your Personal Data: We will provide to You, or a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
   

• Withdraw Your consent: You have the right to withdraw Your consent to use your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

- Exercising Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Our Service only addresses people under the age of 13. We do not knowingly collect personally identifiable information from anyone under 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. Suppose We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent. In that case, We take steps to remove that information from Our servers.

We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Our Service may contain links to other websites we do not operate. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will inform you via email and/or a prominent notice on Our Service before the change becomes effective and update the 'Last updated' date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. This Privacy Policy changes are effective when posted on this page.

If you have any questions about this Privacy Policy, You can contact us:

If you have any questions regarding the use we make of your information, the first thing you should do is contact our Data Protection team by

• Emailing us at: gdpr@neuroelectrics.com.

• Visiting this page on our website Neuroelectrics Privacy Policy

By postal mail:

• NEUROELECTRICS BARCELONA, S.L.U. Europe Office Avinguda Tibidabo, 47 bis 08035 Barcelona, Spain.

• US Office 1 Broadway, 14th Floor Cambridge 02142 Massachusetts, USA.

This privacy statement is in accordance with the EU General Data Protection Regulation. We reserve the right to update this privacy statement periodically. The latest version will be published on this page.