Privacy Policy

Overview

Your privacy is important to us. It is Neurovo LLC's ("Neurovo," "we," "us," or "our") policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website https://neurovo.com, our marketing management platform, our Meta developer application, and other sites and services we own and operate.

Personal information is any information about you that can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and information about how you use a website or online service.

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy. This Privacy Policy does not apply to your activities after you leave our site.

Information We Collect

Information we collect falls into one of two categories: voluntarily provided information and automatically collected information.

Voluntarily Provided Information

"Voluntarily provided" information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions. This may include:

• Name, email address, phone number, and mailing address
• Account registration details (job title, practice name, organization)
• Billing and payment information (processed through secure third-party payment processors; we do not store raw payment card data)
• Campaign settings, budget inputs, and targeting preferences configured in our platform
• Communications sent to us via email, phone, or support channels
• Information submitted through contact forms, intake forms, or survey responses

Automatically Collected Information

"Automatically collected" information refers to any information automatically sent by your devices in the course of accessing our products and services. This may include:

• IP address, browser type, operating system, and device type
• Pages visited, time spent, and navigation paths on our website
• Referring URLs and search terms used to find our site
• Log data, session identifiers, and error reports
• Cookies and similar tracking technologies

Meta Platform Data

Neurovo operates a proprietary marketing management application that integrates with Meta's developer platform (including the Meta Marketing API) to manage, analyze, and optimize advertising campaigns on behalf of our clients. When a user or client authorizes our application through Meta, we may receive the following data subject to the permissions granted:

• Account identifiers: Facebook User ID, Business Manager ID, Ad Account IDs, Page IDs
• Profile information: Name, email address, profile picture URL
• Advertising data: Campaign performance metrics, ad sets, creative data, spend data, impressions, clicks, conversion data, and audience insights
• Page data: Facebook Page insights, post performance, follower demographics (aggregated and de-identified)
• Business information: Business name and verification status
• Device and technical data: IP address, device type, browser type, and operating system when accessing our platform
• Advertising ID: Where applicable, as disclosed in the Advertising ID section below

How We Use Information

We use information collected through our website, platform, and Meta developer application solely for the following purposes:

We do not:

• Sell your personal information or Meta platform data to third parties
• Use Meta user data to target advertising beyond the scope of authorized campaign management
• Build or augment individual user profiles beyond what is necessary to deliver our services
• Share data with data brokers
• Use data for any purpose inconsistent with this policy or Meta's Developer Data Use Policy

Advertising ID Disclosure

How We Share Information

We do not sell, rent, or trade your personal information. We may share information only in the following limited circumstances:

Service Providers

We work with trusted third-party service providers who assist in delivering our services, including cloud hosting providers, analytics platforms, CRM systems, and payment processors. These providers are contractually bound to use data only for the purposes we specify, comply with applicable data protection laws, and delete user data when we cease using their services.

Client Authorization

Where a client has explicitly directed us to share data with a specific third party, we may do so pursuant to their documented instruction and solely within the scope of the authorization provided.

Information from Third Parties

If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about someone else, you represent and warrant that you have that person's consent to provide the personal information to us.

Legal Requirements

We may disclose data when required by law, court order, or government authority, or when necessary to protect the rights, safety, or property of Neurovo, our clients, or the public. Where legally permitted, we will notify affected parties of such disclosures.

Meta's Platform

As a registered Meta developer, certain data is exchanged with Meta as part of API interactions in accordance with Meta's Platform Terms. Our use of that data is governed by Meta's Developer Data Use Policy in addition to this policy.

Data Retention

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy:

• Active account data: Retained for the duration of the client relationship plus 12 months following termination
• Campaign and advertising performance data: Retained for up to 36 months; thereafter aggregated and de-identified
• Meta platform user data: Deleted without undue delay when (a) no longer necessary; (b) a user requests deletion; (c) deletion is requested by Meta; or (d) applicable law requires deletion
• Contact and support communications: Retained for up to 24 months
• Financial records: Retained for the period required by applicable tax and financial regulations

If your personal information is no longer required, we will delete it or make it anonymous by removing all details that identify you. We may retain information for compliance with a legal, accounting, or reporting obligation, or for archiving or statistical purposes where permitted by law.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Our security measures include:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Role-based access controls limiting data access to authorized personnel only
• Regular security assessments and vulnerability monitoring
• Employee training on data security and privacy obligations
• Incident response procedures in the event of a data breach

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security. You are responsible for selecting a strong password and maintaining the security of your own account credentials.

We will comply with laws applicable to us in respect of any data breach, and will notify affected individuals and relevant authorities as required.

Your Rights and Controlling Your Personal Information

Your Choice

By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us; however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.

Access

You may request details of the personal information that we hold about you at any time by contacting us using the details below.

Correction

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-Discrimination

We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer, we will not deny you goods or services, charge different prices, or provide you with a different level or quality of service.

Marketing Permission and Opt-Out

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below, or by using the opt-out link provided in any marketing communication.

Complaints

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide full details of the alleged breach. We will promptly investigate your complaint and respond to you in writing. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe

To unsubscribe from our email database or opt out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Data Deletion Requests

You have the right to request deletion of your personal data at any time. Upon receiving a verified deletion request, we will acknowledge receipt within 5 business days, complete deletion within 30 days (subject to legal retention obligations), notify our service providers to delete data held on our behalf, and confirm completion in writing.

1. By Email Send a request to [email protected] with the subject line "Data Deletion Request." Include your name, email address, and your relationship with Neurovo (e.g., website visitor, client, authorized user).
2. By Phone Call us at (800) 834-5172 during business hours to initiate a deletion request. We will document your request and follow up in writing.
3. By Written Mail Send a written request to: Neurovo LLC, Attn: Privacy Officer, 800 S Gay St, Suite 700, Knoxville, TN 37929.

We will retain only data required by law or necessary to resolve disputes and enforce agreements. Deletion of certain data may affect your ability to use some features of our services.

GDPR Legal Basis for Processing

For users located in the European Economic Area (EEA) or United Kingdom, our legal bases for processing personal data under the General Data Protection Regulation (GDPR) are:

• Contractual necessity: Processing required to deliver our services under the client agreement
• Legitimate interests: Analytics, security, fraud prevention, and platform improvement — where these do not override individual rights
• Legal obligation: Compliance with applicable laws and regulations
• Consent: Where we rely on your explicit consent, you may withdraw it at any time without affecting the lawfulness of prior processing

California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information:

• Right to Know: The categories of personal information collected, the purposes for collection, and whether information is sold or disclosed
• Right to Delete: Request deletion of personal information we have collected (subject to exceptions)
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: We do not sell or share personal information as defined under CCPA/CPRA
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information for purposes beyond service delivery
• Right to Non-Discrimination: We will not discriminate against you for exercising any CCPA/CPRA rights

To submit a California privacy request, email [email protected] with "California Privacy Request" in the subject line, or call (800) 834-5172. We will verify your identity before processing any request.

Meta Platform Compliance

As a registered Meta developer, Neurovo LLC agrees to and complies with Meta's Platform Terms, Developer Data Use Policy, and all applicable Meta developer policies. Specifically:

• We use Meta Platform data only for the purposes described in this policy and in accordance with Meta's Developer Data Use Policy
• We do not sell Meta user data or use it for any purpose prohibited by Meta's policies
• This policy is maintained at a publicly accessible, HTTPS URL that is not geo-blocked and is accessible to Meta's web crawlers
• We will update this policy promptly if our data practices change
• We respond promptly to data deletion requests submitted by Meta on behalf of users
• We maintain a link to this policy in our Meta App Dashboard and all applicable app submissions
• We complete required Data Use Checkups (DUC) and Data Protection Assessments (DPA) on the schedules required by Meta
• We obtain valid user consent before building or augmenting user profiles through Meta data

International Data Transfers

Neurovo LLC is based in the United States. If you are located in the European Economic Area (EEA), United Kingdom, Australia, or another jurisdiction with data transfer restrictions, please be aware that data you provide may be transferred to and processed in the United States.

Where we transfer data from the EEA or UK, we rely on appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission, or other legally recognized transfer mechanisms. Copies of relevant safeguards are available upon request.

Additional Disclosures for Australian Privacy Act Compliance

Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles. You acknowledge that if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

Children's Privacy (COPPA)

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13. Our application and services are directed exclusively to business professionals — practice owners, administrators, and marketing staff.

If we become aware that we have inadvertently collected personal data from a child under 13, we will promptly delete such information. If you believe we may have collected data from a minor, please contact us immediately at [email protected].

HIPAA Note for Mental Health Practices

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information. We will provide reasonable notice of any such transfer.

Third-Party Links and Services

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices. After following a link to any third-party content, you should read their posted privacy policy.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy and update the "Last Updated" date.

When we make material changes, we will notify active clients and registered users via email or in-app notification at least 14 days before changes take effect. If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

This privacy policy is maintained at a publicly accessible, non-geo-blocked HTTPS URL accessible to Meta's web crawlers per Meta Platform Terms (effective February 3, 2025). Version 3.0 — Last updated March 4, 2026.