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COOKIE POLICY FOR NEUROSANTE B.V.

Effective Date: 06.11.2024

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At NEUROSANTE B.V., we are committed to being transparent about the technologies we use on our website (www.neuroces.com). This Cookie Policy explains what cookies are, how we use them, and how you can manage your cookie preferences.

1. What Are Cookies?

Cookies are small text files placed on your device (such as your computer, tablet, or smartphone) by a website you visit. These files store and retrieve information about your interactions with the website, helping the website to function correctly, enhance user experience, and provide certain functionalities.

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Cookies can be classified according to their purpose, origin, and duration:

1.1. Purpose

  • Strictly Necessary Cookies: These cookies are essential for the website to operate properly and enable basic functions like page navigation, user login, and secure access to certain areas. As outlined in Article 6(1)(f) GDPR, the use of these cookies is based on our legitimate interest in ensuring the website’s functionality.

  • Performance Cookies: These cookies collect anonymized information about how users interact with the website, helping us to understand which pages are frequently visited and whether users encounter errors. In accordance with Article 6(1)(a) GDPR, explicit user consent is required for these cookies.

  • Functional Cookies: These cookies remember your preferences (such as language settings) to provide a more personalized experience. The legal basis for using functional cookies is Article 6(1)(a) GDPR, requiring explicit consent.

  • Targeting/Advertising Cookies: These cookies track users’ online behavior to deliver targeted advertising. According to Article 6(1)(a) GDPR, explicit consent must be obtained before activating these cookies.

1.2. Origin

  • First-Party Cookies: These cookies are set directly by us, the website owner (www.neuroces.com), to enhance site functionality and user experience.

  • Third-Party Cookies: These cookies are set by external services (such as Google Analytics, Stripe, and Bing Webmaster Tools) that provide additional functionality or analytics to help us optimize the website. Third-party cookies are subject to the same consent requirements as stated in Article 6(1)(a) GDPR.

1.3. Duration

  • Session Cookies: These cookies are temporary and are deleted once you close your browser. They are primarily used to maintain session integrity and improve the browsing experience.

  • Persistent Cookies: These cookies remain on your device for a specified duration or until you manually delete them. They are used to remember user preferences or login credentials, making subsequent visits more convenient. We ensure that their lifespan complies with Article 5(1)(e) GDPR, which requires limiting personal data storage to what is necessary.

Cookies may collect personal data such as IP addresses, browsing behavior, and user preferences. In accordance with Article 7 GDPR, users can withdraw their consent for cookies at any time by adjusting browser settings or managing preferences on our website.

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For more information about your data rights and how we handle your data in accordance with Articles 12-23 GDPR, please visit our Privacy Policy.

2. Types of Cookies We Use

This section outlines the types of data we collect, processing methods, and their purposes, in accordance with the General Data Protection Regulation (GDPR).

2.1. Strictly Necessary Cookies

These cookies are essential for the website to function correctly and cannot be turned off in our systems. They are necessary to provide the services you have requested, such as setting your privacy preferences, logging in, or filling out forms.

  • Example Cookies: Session ID cookies, User authentication cookies

  • GDPR Reference: Article 6(1)(b) – Processing is necessary for the performance of a contract or to take steps prior to entering into a contract.

  • Data Processing: These cookies typically do not store any personally identifiable information. However, they ensure that your experience and interaction with our website remain seamless and secure.

  • Retention Period: These cookies expire at the end of the user session or when you close the browser.

2.2. Performance Cookies

These cookies collect information about how visitors use our website, such as which pages are visited most often and error messages encountered. They help us understand how our website is used and enable us to improve its performance and user experience.

  • Example Cookies: Analytics cookies (Google Analytics, Yandex Metrica)

  • GDPR Reference: Article 6(1)(a) – Consent. We require explicit consent from users to process these cookies.

  • Data Processing: While these cookies may collect IP addresses and browsing behavior, they do so in an anonymized form, and data is aggregated for analytical purposes.

  • Retention Period: Data collected by performance cookies is generally retained for a maximum of 26 months, depending on the analytics service provider.

2.3. Functional Cookies

These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our website. If you do not allow these cookies, some or all of these services may not function properly.

  • Example Cookies: Language preference cookies, Location cookies

  • GDPR Reference: Article 6(1)(a) – Consent. Consent is required before using these cookies.

  • Data Processing: Functional cookies may store personally identifiable information such as user preferences, locations, and custom settings.

  • Retention Period: These cookies can persist for longer periods, up to a year, to remember your preferences for subsequent visits.

2.4. Targeting Cookies

These cookies are set through our site by our advertising partners to build a profile of your interests and show you relevant advertisements on other sites. They work by uniquely identifying your browser and device.

  • Example Cookies: Google AdWords cookies, Facebook Pixel

  • GDPR Reference: Article 6(1)(a) – Consent. Explicit consent is needed for processing targeting cookies.

  • Data Processing: These cookies track your online activity and may collect personally identifiable information, including the websites you visit and interests.

  • Retention Period: The lifespan of targeting cookies varies depending on the advertising platform, but it can range from 30 days to 13 months.

2.5. Social Media Cookies

These cookies are set by social media services that we have added to our site to enable content sharing with friends and networks. They are capable of tracking your browser across other sites and building a profile of your interests.

  • Example Cookies: LinkedIn Insights, Twitter buttons, Facebook Connect

  • GDPR Reference: Article 6(1)(a) – Consent. Users must provide explicit consent for processing.

  • Data Processing: Social media cookies collect user identifiers and interactions with social platforms, enabling personalized social experiences and advertising.

  • Retention Period: These cookies can be retained for up to 24 months, depending on the third-party service's policy.

3. Specific Cookies Used on neuroces.com

4. Managing Cookies

As per the General Data Protection Regulation (GDPR), you have the right to manage the cookies that are placed on your device. We aim to be transparent about our use of cookies, and we respect your choices in accordance with GDPR requirements. The relevant articles include Article 7 (Consent), Article 12 (Transparent Information), Article 21 (Right to Object), and Article 25 (Data Protection by Design and Default).

4.1 Providing Consent (Article 7)

When you first visit our website, you will see a cookie banner that clearly outlines our use of cookies. You have the choice to accept all cookies, customize your preferences, or reject non-essential cookies. By clicking "Accept All Cookies," you provide explicit consent to the use of all cookies. If you choose "Manage Preferences," you can select which types of cookies you consent to, in line with Article 7(3) of the GDPR, which states that consent should be as easy to withdraw as it is to give.

4.2 Withdrawing Consent (Article 7, Paragraph 3)

You can withdraw your consent to the use of cookies at any time by accessing the "Cookie Settings" link found at the bottom of our website. You can modify your preferences to disable any non-essential cookies. This feature aligns with Article 7, Paragraph 3 of the GDPR, which allows users to withdraw consent without affecting the lawfulness of processing based on consent before its withdrawal.

4.3 Objecting to Processing (Article 21)

You have the right to object to the processing of your personal data collected via cookies at any time, as outlined in Article 21 of the GDPR. This includes profiling for marketing purposes. If you wish to object, you can do so through the “Cookie Settings” section or by contacting us at info@neuroces.com. Your objection will be processed immediately, and we will ensure that no further data is collected through the cookies you have objected to.

4.4 Browser-Based Controls (Article 12, Paragraph 1)

You can also manage cookies through your browser settings, where you have the option to block or delete cookies. However, please be aware that blocking all cookies, including strictly necessary ones, might impact the website's functionality. For further transparency, here are specific instructions for managing cookies in major browsers:

  • Google Chrome: Go to "Settings," select "Privacy and Security," then choose "Cookies and other site data." Adjust your settings according to your preferences.

  • Mozilla Firefox: Navigate to "Preferences," select "Privacy & Security," and manage cookies under "Cookies and Site Data."

  • Microsoft Edge: Go to "Settings," select "Cookies and site permissions," and manage your preferences accordingly.

  • Safari: Open "Preferences," click "Privacy," and configure your settings under "Cookies and website data."

4.5 Data Protection by Design and Default (Article 25)

We have implemented measures to ensure that our website only activates non-essential cookies after you have provided explicit consent. This approach is in compliance with Article 25 of the GDPR, which requires data protection to be designed into the development of new processes, products, or services.

4.6 Technical Information on Cookie Management

If you have any issues managing cookies or wish to obtain technical support, please contact us at info@neuroces.com or call us at +31 6 27 83 77 65.

5. Third-Party Cookies

At NEUROSANTE B.V., we use cookies to ensure the optimal performance of our website, enhance user experience, and gather insights for website improvement. Our use of cookies complies with the General Data Protection Regulation (GDPR), specifically addressing the requirements of Article 6 (1)(a), (b), (f) and Recital 30. Below is a detailed description of the types of cookies we use:

Specific Cookies Used on neuroces.com

Cookie Name

Type

Purpose

Duration

XSRF-TOKEN

Necessary

Ensures user browsing security by preventing cross-site request forgery attacks.

Session

hs

Necessary

Ensures website security and fraud prevention

Session

svSession

Necessary

Identifies unique visitors and tracks sessions for site security.

24 months

SSR-caching

Necessary

Indicates how the site was rendered (server or client).

1 minute

_wixCIDX

Necessary

Enables the functionality of the website during user sessions.

3 months

_wix_browser_sess

Necessary

Enables system monitoring/debugging.

Session

TS*

Necessary

Used for security and anti-fraud purposes.

Session

consent-policy

Preferences

Stores user cookie consent preferences.

12 months

bSession

Preferences

Measures system effectiveness and stability during a session.

30 minutes

fedops.logger.sessionId

Preferences

Tracks server performance for debugging purposes.

Session

_ga

Analytics

Used by Google Analytics to distinguish users and collect statistics on website usage.

24 months

_gid

Analytics

Tracks user behavior to generate website usage reports.

24 hours

_gat

Analytics

Throttles request rates to prevent overwhelming Google Analytics.

1 minute

_ym_d

Analytics

Stores the date of the user's first session on the website (Yandex Metrica).

12 months

_ym_uid

Analytics

Identifies users for analytics (Yandex Metrica).

24 months

_fbp

Marketing

Used by Facebook to deliver advertisements based on user behavior.

3 months

_gcl_au

Marketing

Used by Google AdSense for experimenting with advertisement efficiency.

3 months

IDE

Marketing

Used by Google DoubleClick to provide targeted advertising.

12 months

ANID

Marketing

Used for Google ad personalization across the web.

12 months

This list covers the key cookies currently deployed on neuroces.com, along with their specific roles and durations.

6. Changes to This Cookie Policy

At NEUROSANTE B.V., we utilize third-party cookies to enhance website functionality, provide personalized advertising, and collect analytical data to improve user experience. Third-party cookies are managed and set by external providers. This practice involves the sharing of personal data with third parties, and it is subject to GDPR compliance, particularly Articles 6 (Lawfulness of Processing), 26 (Joint Controllers), and 28 (Processors).

5.1 Purpose and Scope (Article 6)

We rely on your explicit consent to deploy third-party cookies, in accordance with Article 6(1)(a) of the GDPR, which states that processing is lawful when the data subject has given consent for specific purposes. Third-party cookies are used for advertising, analytics, and social media integration:

  • Advertising Cookies: These cookies enable us to deliver tailored advertisements that are relevant to your interests. They also help limit the number of times you see an ad and measure the effectiveness of ad campaigns. This involves third parties such as Google AdWords and Bing Ads.

  • Analytics Cookies: These cookies help us understand how visitors interact with our website, enabling us to improve functionality and content. Providers like Google Analytics and Yandex Metrica collect anonymized and aggregated data, including visitor numbers, behavior patterns, and page interactions.

  • Social Media Cookies: These cookies allow for the integration of social media features, enabling you to share content easily. They may be set by platforms like Facebook or Twitter.

5.2 Joint Controllers (Article 26)

In cases where we share personal data collected through cookies with third parties that jointly determine the purposes and means of processing, we are considered "joint controllers" as per Article 26 of the GDPR. We have entered into joint controller agreements with these parties, ensuring that responsibilities for GDPR compliance are clearly defined and transparent.

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If you wish to understand the specific roles and responsibilities of NEUROSANTE B.V. and any third-party joint controllers, you may request more information by contacting us at info@neuroces.com.

5.3 Data Processing Agreements (Article 28)

For third-party cookies related to service providers that act as "processors," we ensure compliance with Article 28 of the GDPR. This includes the implementation of data processing agreements (DPAs), which establish the roles, obligations, and technical and organizational measures required to safeguard your data.

5.4 Data Transfer and Compliance (Chapter V of the GDPR)

Third-party cookies may involve the transfer of personal data to countries outside the European Economic Area (EEA). Such transfers are only made in compliance with Chapter V of the GDPR, which includes the use of appropriate safeguards, such as:

  • Standard Contractual Clauses (SCCs)

  • Adequacy Decisions by the European Commission

  • Binding Corporate Rules (BCRs)

You can obtain further information about these transfers by reviewing the privacy policies of the respective third-party providers:

5.5 Right to Object (Article 21)

You have the right to object to the processing of personal data collected via third-party cookies, as described in Article 21 of the GDPR. You can do this by changing your cookie preferences through our “Cookie Settings” or by contacting us directly at info@neuroces.com.

5.6 Transparency and Further Information (Article 12)

We are committed to providing transparent information about the use of third-party cookies. If you have questions or require detailed information on how third-party cookies operate on our website, please contact us at info@neuroces.com or call +31 6 27 83 77 65.

7. Contact Us

NEUROSANTE B.V. reserves the right to update this Cookie Policy to reflect changes in our practices, regulatory requirements, or technological developments. This section is designed in compliance with the General Data Protection Regulation (GDPR), specifically focusing on Articles 12 (Transparent Information), 13 (Information Provided to the Data Subject), and 24 (Responsibility of the Controller).

6.1 Transparency in Policy Changes (Article 12)

In accordance with Article 12 of the GDPR, any changes to this Cookie Policy will be communicated clearly and transparently. We aim to ensure that our users are informed about how cookies are managed and how updates to this policy may affect their data processing and rights. This approach aligns with our commitment to provide information in a concise, transparent, and easily accessible format.

6.2 Notification of Changes (Article 13, Paragraph 3)

We will notify users of significant changes to this Cookie Policy by placing a prominent notice on our website, in accordance with Article 13, Paragraph 3 of the GDPR, which requires controllers to inform data subjects of any changes to the information provided. Depending on the nature of the changes, notifications may include:

  • Banner Notification: Displayed at the top or bottom of our website to ensure visibility.

  • Email Notification: If significant changes are made, we may notify registered users via email, provided we have obtained their contact information.

The changes will become effective on the date specified in the updated policy, and your continued use of the website after the effective date will constitute your acceptance of the revised policy.

6.3 Review of Consent (Article 7, Paragraph 3)

If changes to this Cookie Policy involve the processing of additional types of cookies or significant alterations to data processing purposes, we will seek your renewed consent. This aligns with Article 7, Paragraph 3 of the GDPR, which requires the withdrawal of consent to be as simple as giving consent. You will be able to review and modify your consent through our “Cookie Settings.”

6.4 Ongoing Responsibility (Article 24)

As the data controller, NEUROSANTE B.V. takes full responsibility for ensuring that this Cookie Policy remains compliant with GDPR requirements, as outlined in Article 24. We conduct regular reviews of our cookie practices to ensure they align with regulatory updates and best practices. We update this policy accordingly and ensure that our users are aware of any implications for their data processing rights.

6.5 How to Obtain More Information

If you have questions or concerns about updates to this Cookie Policy, you may contact us:

  • Email: info@neuroces.com

  • Phone: +31 6 27 83 77 65

  • Address: Snellius 1, 6422 RM Heerlen, Netherlands

If you have any questions, concerns, or requests regarding this Cookie Policy or your data protection rights under the General Data Protection Regulation (GDPR), you can contact us through the following means. This section is designed in compliance with Article 12 (Transparent Information), Article 13 (Information Provided to the Data Subject), and Article 15 (Right of Access).

7.1 Right to Transparent Communication (Article 12)

In accordance with Article 12 of the GDPR, NEUROSANTE B.V. aims to provide clear and transparent communication regarding the processing of your personal data through cookies. We ensure that our contact details are easily accessible to allow for effective communication. You can reach us via:

  • Email: info@neuroces.com

  • Phone: +31 6 27 83 77 65

  • Address: Snellius 1, 6422 RM Heerlen, Netherlands

We will respond to your inquiries promptly and provide additional information or guidance, where necessary, regarding the use of cookies and your data protection rights.

7.2 Information Provided to the Data Subject (Article 13)

As outlined in Article 13 of the GDPR, we are obligated to provide you with the means to inquire about the processing of your data. You may contact us to request further information about:

  • Types of cookies used and their specific purposes.

  • The basis for processing of any personal data collected through cookies, including how consent is obtained and managed.

  • Transfers of personal data to third parties, including any international transfers and the safeguards in place.

7.3 Right of Access (Article 15)

If you wish to exercise your right of access under Article 15 of the GDPR, you may contact us to obtain:

  • Confirmation of whether we process your personal data collected through cookies.

  • Access to the personal data collected through cookies, including the categories of data and the purposes of processing.

  • Information on data retention periods, third-party recipients, and the mechanisms for international data transfers, if applicable.

You can make these requests via email or by writing to us at the address provided above. We will respond within one month of receiving your request, as mandated by the GDPR.

7.4 Complaints or Concerns (Article 77)

If you believe that your rights under the GDPR have been violated regarding cookie usage or any other data processing activity on our website, you have the right to lodge a complaint with a supervisory authority. In the Netherlands, you can contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

Alternatively, you may contact the supervisory authority in your place of residence if you are located in another EU/EEA country.

7.5 Data Protection Officer (DPO)

You may also contact our Data Protection Officer (DPO) regarding cookie-related queries or concerns. If you have questions, concerns, or requests related to data protection or this cookie policy, you can contact our Data Protection Officer:

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Name: Selim Akdemir

Email: info@neuroces.com

Phone: +31 6 27 83 77 65

Address: Snellius 1, 6422 RM Heerlen, Netherlands

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